Financial Conflicts of Interest -Frequently Asked Questions
1. How do I know if my Significant Financial Interests are related to my Institutional Responsibilities?
Investigators must disclose those Significant Financial Interests (SFI) that “reasonably appear to be related” to the investigator’s institutional responsibilities. Each investigator can reasonably judge whether or not any given SFI is related to his or her institutional responsibilities. Investigators need to ask whether their research or institutional responsibilities could affect the value of the financial interest or could have a financial impact on the entity in which they hold the financial interest. Generally, income received from consulting or speaking on behalf of an entity is always related because the investigator has been retained as a consultant based on their overall experience in the field. If an entity in which an SFI is held is involved in the same research project (e.g., via a subcontract), then it is considered related to the investigator’s institutional responsibilities.
2. Must I list my entire research portfolio in the disclosure, or only those projects which are closely related to my SFI?
Research projects listed in your disclosure should be those which affect any given SFI or the financial interest of an entity. This means that the value of the SFI could increase or decrease or a relationship extended or terminated, based on the results of the research. If this is the case, the project should be added to the disclosure as related to each SFI it could affect. Research as related must be disclosed if there is a possibility for any of these effects to occur, even if they do not actually occur. This is similar to the way an investigator determines whether an SFI is related to his or her institutional responsibilities. Examples of research projects that are related to SFI in this way include, but are not limited to:
You are a paid consultant to ABC company, which also subcontracts a portion of a research project to your Georgia Southern Laboratory or you subcontract a portion of the research to ABC Company;
You are a paid speaker for ABC Company, and also the principal investigator of a Georgia Southern research project funded by ABC Company;
You own >$5,000 worth of stock in ABC Company and also conduct research to test the products of ABC Company;
ABC Company has paid for travel for you and you also conduct research at Georgia Southern University that is likely to develop IP that would be of interest to ABC Company;
You own stock in ABC Company and ABC Company provides cost-sharing on an award in your laboratory at Georgia Southern University.
3. Does salary support or travel on a sponsored award need to be disclosed?
Any funds coming through the University’s Office of Research Services and Sponsored Programs do not constitute SFI and do not need to be disclosed. Such funding is not considered an outside financial interest because it supports your role at the University.
4. What if I receive salary support or travel expenses on a sponsored award from an industry entity?
Funds coming from an industry entity do not need to be disclosed if they are part of a sponsored award at the University (see also question 3).
If I receive an honorarium or other payment from another university, does that need to be disclosed?
Income from U.S. institutions of higher education, teaching hospitals or research centers affiliated with the above, is not included un SFI and does not need to be disclosed. Honoraria or payments from foreign institutions MUST be disclosed.
5. Does income from a government agency need to be disclosed?
Income from a U.S. federal, state, or local government agency is not included in SFI and does not need to be disclosed. Income from a foreign government agency DOES need to be disclosed.
6. Does income from foreign institutions of higher education or foreign governments need to be disclosed?
Yes. (see also questions 5-6).
7. Does income from a non-profit or not-for-profit organization need to be disclosed?
Federal regulations require income and travel from non-profit or not-for-profit organizations to be disclosed.
Do honoraria or travel from a professional society need to be disclosed?
Professional societies are considered non-profit organizations, travel and income from them require disclosure. (see also question 8).
8. I sit on a study section at NIH/NSF/etc. Does my income from that need to be disclosed?
No. U.S. government funding agencies are government sources, income from service on a study section do not require disclosure. However, if you serve on a proposal review board for a non-profit entity, such as a foundation, any income over $5,000 is considered SFI and MUST be disclosed. (See also questions 6 and 8.)
9. I sit on an editorial board for a journal. Does my income from that need to be disclosed?
Disclosure depends on whether the journal is a private organization, or if it is published by a U.S. government agency or a U.S. institution of higher education. Follow the same guidelines as for other income. (See also questions 5, 6, and 8).
10. I receive royalties or licensing income from a patent that is owned by Georgia Southern University Research and Service Foundation, Inc. (“GSURSF”). Do I need to disclose that?
No. Royalties or other payment received from the University or GSURSF is not considered SFI and does not need to be disclosed.
11. Do royalties from a publisher need to be disclosed?
Disclosure depends on the nature of the publication. Royalties from a textbook or other publication that is relevant to your role at the University do not need to be disclosed. However, royalties for a more popular title, or for something which is marketed widely, such as a K-12 curriculum, do require disclosure if it exceeds $5,000 in the past twelve months.
12. What about mutual funds or other investments, such as those through TIAA-CREF?
Investments, such as mutual funds, in which an investigator does not have control over the individual securities held, are excluded from SFI and do not require disclosure. If you own other investments, such as stock in an individual corporation, even if held in a retirement account, those investments can be bought or sold at your discretion, and you will need to evaluate each such investment in order to determine whether it is reasonably related to your Institutional Responsibilities (See also question 1).
13. What if someone from a business comes to campus and takes me to lunch to discuss my research? Must I disclose that?
The lunch would be considered a gift and could be disclosed if, in conjunction with other compensation or any equity in the company, you exceed the $5,000 threshold for the past twelve months. However, if the lunch (gift) is the only financial interest you have in the company, then it would not need to be disclosed. This is not considered a travel expense as the lunch occurred locally. Also, if you receive meals while travelling, disclosure for them is not required, but can be included in the total expense of the trip if you know the cost.
14. Does income from service as an expert witness need to be disclosed?
Income from service as an expert witness should be disclosed if it relates to the investigator’s institutional responsibilities. If the work you perform as an expert witness is based on your general expertise but does not relate directly to specific work that you perform at the University, the compensation does not need to be disclosed. However, if the work you perform as an expert witness does directly relate to a specific research project(s) or to other activities you are involved in, such as purchasing decisions, then compensation should be disclosed.
Last updated: 9/29/2016