Do I have to file a Certification?
If you meet the federal definition of Investigator and you seek or receive external funds for research, 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 is a Significant Financial Interest for non-PHS funded Investigators?
Significant Financial Interests (SFI) include certain payments, ownership interests and intellectual property rights and interests. SFI includes:
- An ownership interest that exceeds $10,000 in fair market value and represents more than 5% ownership in a single publicly-traded entity.
- Any ownership interest in a single privately-held entity.
- Salaries, consulting fees, royalties, and other payments that when aggregated over the next twelve month period are expected to exceed $10,000.
What are Significant Financial Interests for PHS disclosures?
“Significant Financial Interests” (SFI) include certain payments, ownership interests and intellectual property rights and interests. SFI includes:
- 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. Additionally, you should disclose if you have any equity interest in the entity such as stock, stock options or other ownership interest.
- A Significant Financial Interest exists when you have income from intellectual property rights and interests such as patents and copyright, upon receipt of income, where the payments are not from CMU.
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.
Are there any financial interests that do not have to be reported?
- Income from investments such as mutual funds or retirement accounts where you cannot directly control investment decisions;
- Salary, compensation, royalties or other payments from CMU;
- Income from seminars, lectures or teaching engagements sponsored by public or nonprofit entities in the United States;
- Income from service on advisory committees, or review panels for public or non-profit entities in the United States.
What is not a Significant Financial Interest for PHS disclosure?
- 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 throughout the course of an award. The regulation states that Investigators must update financial disclosures within thirty (30) days of acquiring or discovering a new SFI. Once disclosed, CMU has 60 days to review the disclosure and determine whether the SFI is related to your research, if a COI exists, and to manage the COI and report to the funding agency.
You do not need to disclose ongoing fluctuations in the value of your previously disclosed SFIs. 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.