Carnegie Mellon University
If you meet the federal definition of Investigator and you seek or receive external funds for research, you need to complete an Annual Certification and a Research Certification prior to proposal submission, using the SPARCS COI system. 

For most externally funded researchers disclosure of Significant Financial Interests that create a potential conflict of interest is required.  For researchers seeking or receiving PHS funding, disclosure of Significant Financial Interests related to Institutional Responsibilities are required. For researchers who work, at or collaborate on research, with the Software Engineer Institute, all financial interests over a specific dollar threshold must be disclosed, according to the SEI's own conflict of interest policy.

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 entity.
  • Salaries, consulting fees, royalties, and other payments that when aggregated over the next twelve month period are expected to exceed $10,000.

“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.

Yes.

  • Income from investments such as mutual funds or retirement accounts where you do not 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 Staets. 
  • 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 government agency, an institution of higher education, an academic teaching hospital, medical center or research institute affiliated with an institution of higher education
  • Income from service on an advisory committee or review panel for a government agency, an institution of higher education, an academic teaching hospital, medical center or research institute affiliated with an institution of higher education

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.

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.