August 3, 2012
What are the Major Changes due to the New Policy?
- The annual disclosure will begin August 10, 2012.
- Financial conflict of interest (FCOI) training is required prior to completing the annual FCOI form which is included within the form.
- Annual disclosure reporting is based on remuneration received in the twelve months preceding the disclosure date.
- ALL significant financial interests of the Discloser and the Discloser’s spouse and dependent children that reasonably appear to be related to the Discloser’s university responsibilities must be reported.
- It is the obligation of the Institution to determine if the interest(s) reported are a financial conflict of interest.
- The de minimis threshold for reporting significant financial interest(s) is $5,000 for all researchers, including those participating in research involving human subjects.
- Disclosure of any equity ownership in non-publicly traded entities, including faculty start-up companies, is required.
- Any reimbursed or sponsored travel related to university responsibilities must be disclosed.
- Disclosers must submit an updated disclosure of a significant financial interest within thirty days of acquiring a new interest or a change to an existing interest.
- The public will have access to information in relation to financial conflicts of interests that related to a Discloser’s research sponsored by the federal government.
What to Expect?
- Prior to accessing the 2012/2013 financial conflict of interest disclosure form, the Discloser must complete FCOI training by viewing and affirming the receipt of the training slides found at the beginning of the disclosure form.
- Due to the additional reporting required by the new federal regulations on financial conflict of interest, additional questions will be included on the conflict of interest disclosure form going forward.
- COI Informational Sessions will be offered throughout the summer and early fall.
- Department chair input will be requested related to the significant financial interests that were reported by their researchers.