GE0002 Disclosures for Research Activities

GE0002 | DISCLOSURES FOR RESEARCH ACTIVITIES

The chart below provides a high-level overview of disclosure requirements in research if federally sponsored by the Public Health Service (PHS) and those sponsors enforcing the same requirements. UT has adopted the PHS disclosure requirements which are reflected in the OID Form.

Together, we can help ensure that your research is conducted in an open academic environment and continues without interference, bias, restrictions on results, or any burdens on personnel, students, and facilities.

Category

PHS and Agencies Using PHS Requirements

Disclosure Events

  • PHS research contract/grant
  • Non-governmental entity which flows down PHS funds
  • Research funding from organizations that follow PHS disclosure requirements

Key Terms/Thresholds

A significant financial interest (SFI) is defined by PHS as:

  • If publicly traded entity, value of compensation and equity interest, in aggregate, > $5,000
  • If non-publicly traded entity, total value of compensation > $5,000 or any equity interest, regardless of value
  • Income received related to intellectual property > $5,000
  • Reimbursed or sponsored travel > $5,000
  • Includes SFIs of the Investigator and the Investigator’s spouse and dependent children that are related to the Investigator’s “institutional responsibilities”

Additional information regarding the National Institutes of Health (NIH) requirements for disclosing SFIs can be found within NIH Grants and Funding FAQs, Section E.

Timing


  • With the initial and renewal proposals

  • With supplemental funding proposal

  • With non-competing continuation

  • With no cost time extension

  • When a new researcher/investigator(s) is added

  • At least annually for duration of project

  • With any new significant financial interest

  • Within thirty (30) days of acquiring or discovering a new SFI or an SFI that was not disclosed timely.

  • With any discovery of a SFI that was not previously identified/managed, a retrospective review must be conducted in accordance with NIH requirements. Please see steps identified within the NIH Grants and Funding FAQs, Section I.

Additional information regarding the NIH requirements can be found at 42 CFR § 50.605 Management and reporting of financial conflicts of interest and § 50.606 Remedies.

NOTE: Other federal and state agencies, including the National Science Foundation (NSF), industry sponsors, and non-profit research associations may have their own standards for disclosure and it is important that you understand them if you engage in research with a particular agency.

Always ask a supervisor or contact a subject matter expert if you have any questions or concerns. When in doubt, disclose.


GE0002 Disclosures for Research Activities
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