Forms and Instructions

Significant Financial Interest Disclosure Instructions

What is required?

NSF and PHS regulations require institutions to have policies and procedures in place that ensure that Investigators disclose any Significant Financial Interest that may present an actual or potential conflict of interest in relationship to externally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding,* and institutions must develop specific mechanisms by which conflicts of interest will be satisfactorily managed, reduced, or eliminated prior to any award expenditures. *If a new reportable Significant Financial Interest arises at any time during the period after the submission of the proposal through the period of the award, the filing of a disclosure and supporting documentation is also required.

Who is covered?

"Investigator" means the principal investigator/project director, co-principal investigators, and any other person at the University who is responsible for the design, conduct, or reporting of research or educational activities funded, or proposed for funding. In this context, the term "Investigator" also includes the Investigator's spouse and dependent children.

What must be disclosed?

Each Investigator shall disclose all Significant Financial Interests:

1. that would reasonably appear to be affected by the research or educational activities funded, or proposed for funding, by an external sponsor; or
2. in entities whose financial interests would reasonably appear to be affected by such activities.

What is covered?

"Significant financial interests" means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).

What is exempt?

1. Salary, royalties, or other remuneration from University;
2. income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
3. income from service on advisory committees or review panels for public or nonprofit entities; or;
4. financial interests in business enterprises or entities if the value of such interests do not exceed $10,000 (or $10,000 per annum if such interests represent salary, fees or other continuing payments) and represent more than 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's spouse and dependent children.

1. All Investigators must disclose their Significant Financial Interests utilizing this form and attaching all required supporting documentation. The completed form and packet must be submitted with the proposal to the Department Chair or unit Director. Supporting documentation should be submitted in a sealed envelope marked confidential. After review by the Chair or any review committee, this material will be forwarded for inclusion in the University grant file.
2. In accordance with federal regulations, a complete disclosure must be made by Investigator(s) prior to submission of the proposal.
3. Resolutions of conflicts of interest will be incorporated in a Memorandum of Understanding (MOU) that is executed between the Investigator(s) and the Dean/Director prior to any award expenditures.
4. Please refer to the more detailed "Instructions for Handling Significant Financial Interest Disclosures for PHS and NSF Sponsored Projects" available at ORSP and departmental offices for further information.

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