Is CMU compliant with the PHS FCOI regulations?
Is CMU compliant with the DOE Interim COI policy
Do I have to file a Certification?
If you meet the definition of Investigator given in the Guidelines, you need to complete an Annual Certification using the SPARCS COI system. You also need to complete Research Certifications if asked to do so by ORIC.
What happens if a conflict of interest Certification is not completed?
When you receive a new award, the Office of Sponsored Programs will verify that you have a complete and unexpired Annual Certification on file, and that any Research Certifications specific to this project are also completed and reviewed. If these have not been completed, you will be notified by ORIC and/or OSP. You will not be able to begin spending on the new award until your Certifications are completed and reviewed, and any necessary conflict of interest management plans are in place.
Which types of financial interest need to be disclosed?
The most common types of disclosed financial interests are company ownership, consulting income, and stock holdings. It's possible, but less common, that you might have to disclose other types of interests such as income from royalties. Other than a few specific exceptions detailed later in this FAQ, it doesn't matter whether the financial relationship is with a U.S. or foreign entity; both must be disclosed.
What are Significant Financial Interests?
“Significant Financial Interests” (SFI) include certain payments, ownership interests and intellectual property rights and interests held by an Investigator, the Investigator's spouse or domestic partner, or the Investigator's dependent children. Details and examples are included in the COI Guidelines and in the SPARCS system. SFIs include:
- A Significant Financial Interest exists, related to a publicly traded company, if the value of any compensation or payment in the preceding twelve (12) months and the value of any equity interest as of the date of this disclosure, when aggregated and exceeds $5,000. This includes salary, payment for services, stock, stock options or other ownership interest.
- A Significant Financial Interest exists, related to a privately held company, if the value of any compensation or payment in the preceding twelve (12) months exceeds $5,000, or if there is any equity interest in the entity such as stock, stock options or other ownership interest.
- A Significant Financial Interest exists when the Investigator, spouse/partner, or dependent children have income from intellectual property rights and interests such as patents and copyright, upon receipt of income, where the payments are not from CMU.
- A Significant Financial Interest exists, related to sponsored or reimbursed travel, when a single entity pays for or reimburses $5,000 or more in travel expenses in the preceding twelve (12) months. There are several exceptions for types of travel that do not need to be reported, detailed in the Guidelines.
How precise do my dollar amounts need to be?
SPARCS will ask you to provide specific dollar amounts for most of your financial interests, other than ownership of a private company. We ask that you provide information as accurately as possible but understand that you may not know, for example, the exact value of a stock holding on the specific date that you are completing a Certification, or that if you are reporting anticipated consulting income the exact amount of payment may not be known yet. You may provide a dollar amount from your most recent quarterly brokerage statement, or estimate expected income to the best of your ability. If ORIC determines that your financial interest poses a potential conflict of interest, you may be asked to provide more up-to-date or detailed information during the COI review process.
What is not a Significant Financial Interest?
- Salary, royalties, or other payments from CMU.
- Income from investments such as mutual funds or retirement accounts where you do not directly control investment decisions.
- Income from seminars, lectures, or teaching engagements sponsored by a U.S. government agency, a U.S. institution of higher education, or a academic teaching hospital, medical center or research institute affiliated with a U.S. institution of higher education
- Income from service on an advisory committee or review panel for a U.S. government agency, a U.S. institution of higher education, an academic teaching hospital, medical center or research institute affiliated with a U.S. institution of higher education
My financial interests change periodically. When do I have to update my disclosure?
You have an ongoing obligation to disclose your SFI. The Guideslines state that Investigators must update financial disclosures within thirty (30) days of acquiring or discovering a new SFI. .
You do not need to disclose ongoing fluctuations in the value of your previously disclosed SFIs more frequently than annually. Annual updates are sufficient in most cases. If a more recent update is needed to manage a specific conflict, ORIC will ask you to provide additional detail.
What is a Financial Conflict of Interest?
Conflicts of interest in research occur when university members are in a position to influence research and their extramural activities are such that they or their family may receive a financial benefit or improper advantage from the research.