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An individual who, regardless of title or position, is responsible for the design, conduct, or reporting of research, including a principal investigator, co-investigator, or project director, must file and update financial disclosure statements under this policy. A person required to file and update financial disclosure statements is referred to in this policy as a “covered individual.”

 A student enrolled at the University who is responsible for the design, conduct, or reporting of research that is not PHS-funded is considered to be a “covered individual” under this policy only if the student has a significant financial interest that appears to be affected by the research or is in an entity whose financial interest appears to be affected by the research. A student who is in doubt about whether the student is a “covered individual” must request a determination by the conflict of interest official.

The following interests are considered to be significant financial interests and, subject to the exclusions provided by Subsection 2.2.2.2 of section IV, Ch. 2 of the ¹û½´ÊÓƵ HOOP (listed below), a covered individual’s disclosure statement must include the following information in regard to the covered individual and covered family members,  but only in regard to interests that reasonably appear to be related to the individual’s institutional responsibilities:

1. PAYMENTS RECEIVED FROM OR EQUITY INTEREST IN A PUBLICLY TRADED ENTITY: the total amount and source of payments received in the preceding twelve months from a publicly traded entity and the value of any equity interest held in the entity on the date of disclosure that, when aggregated, exceed $5,000, including:
   1. as to payments received:
      1. salary; and
      2. any payment for services other than salary, such as consulting fees, honoraria, or paid authorship; and
   2. as to equity interests held, any stock, stock options, or other ownership interest or entitlement to such an interest, valued by reference to public prices or other reasonable measures of fair market value;
2. PAYMENTS RECEIVED FROM A NON-PUBLICLY TRADED ENTITY OR EQUITY INTEREST IN A NON-PUBLICLY TRADED ENTITY:
   1. the total amount and source of payments received in the preceding twelve months from an entity that is not publicly traded that, when aggregated, exceed $5,000, including
      1. salary; and
      2. any payment for services other than salary, such as consulting fees, honoraria, or paid authorship; and
   2. a description of any equity interest held in an entity that is not publicly traded, including any stock, stock options, or other ownership interests or entitlement to such an interest;
3. INTELLECTUAL PROPERTY AND ROYALTIES:
   1. a description of intellectual property rights held and any agreements to share in royalties related to those rights; and
   2. the amount and source of royalty income that the covered individual or covered family member received or had the right to receive in the preceding twelve months;
4. TRAVEL: reimbursed or sponsored travel in the preceding 12 months, including the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration;
5. GIFTS: the value and source of a single gift that the covered individual received in the preceding twelve months that exceeds $250 in value, or multiple gifts from a single entity that in the aggregate exceed $250 in value, other than gifts from a covered family member; and
6. FIDUCIARY POSITIONS: a fiduciary position the covered individual held in a for-profit or nonprofit entity in the preceding twelve months, including a position as a member of the board of directors, an officer, or other executive or management position, for which the individual received any form of remuneration or reimbursement for expenses, and the name and principal address of the entity.

In making disclosures under this Section 2.2.2, the covered individual shall disclose the value of a significant financial interest within the following ranges:

1. $0 - $4,999;
2. $5,000 - $9,999;
3. $10,000 - $19,999;
4. amounts between $20,000 - $100,000 by increments of $20,000; or
5. amounts above $100,000 by increments of $50,000.

A covered individual shall submit or update a financial interest disclosure statement:

1. not later than the 30th day of initial employment, covering the 12 months preceding the date of disclosure;
2. annually, during the annual reporting period (January through March); and
3. not later than the 30th day after acquiring a new financial interest that requires disclosure, such as receiving payments, an equity interest, intellectual property rights, or royalties that would require disclosure on an annual financial interest disclosure statement.

The following interests are not significant financial interests and need not be disclosed on the disclosure statement:

1. salary, royalties, or other remuneration paid by the University to the covered individual, if the covered individual is currently employed or otherwise appointed by the institution;
2. income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government, an institution of higher education as defined by 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute affiliated with an institution of higher education;
3. income from service on an advisory committee or review panel for a federal, state, or local government, an institution of higher education as defined by 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute affiliated with an institution of higher education;
4. income from investment vehicles, such as mutual funds or retirement accounts, as long as the covered individual does not directly control the investment decisions made in those vehicles; or
5. travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined by 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

The appropriate conflict of interest official shall review each financial interest disclosure statement and make two determinations:

1. whether any significant financial interest disclosed is related to research in which the covered individual is engaged; and
2. if so, whether a financial conflict of interest exists.

A significant financial interest is related to research in which the covered individual is engaged if the conflict of interest official reasonably determines that the financial interest appears to be affected by the research or is in an entity whose financial interest appears to be affected by the research.

A financial conflict of interest exists when the conflict of interest official reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of the research.

In order for the University to maintain public trust and support in carrying out its research mission, the University must demonstrate that it subjects itself to the highest standards of ethical behavior. Situations in which financial consideration may compromise, or have the appearance of compromising, an investigator’s professional judgement in the design, conduct, or reporting of research must be managed or mitigated when they occur.

The University’s policy on Financial Conflicts of Interest (FCOI) in Research promotes objectivity in research by establishing standards to ensure the design, conduct, or reporting of research will not be biased by any conflicting financial interest of an investigator.

While the University encourages investigators to engage in appropriate outside relationships, all investigators must, in accordance with University policy, disclose any significant financial interests (including those of a spouse and/or dependent child) that relate to the investigator’s institutional responsibilities and, if applicable, comply with financial conflict of interest management or mitigation plans.

Timely, complete, and accurate disclosure of activities and financial interests consistent with this policy is a condition of employment at the University, and a covered individual who does not comply with this policy is subject to discipline, including termination of employment.