Updated Financial Conflict of Interest Disclosures
Based on changes in the federal regulations, Office of Research has updated the Financial Conflict of Interest disclosure process.
What is a Significant Financial Interest, and why is it important?
All Significant Financial Interests (SFIs), except for the six (6) exclusions listed in Drexel’s Policy on “Managing Conflicts of Interests in Sponsored Projects” (Drexel Policy) must be disclosed. The following breakdown of the definition of a SFI is provided to assist in the determination of whether a financial interest is deemed a SFI and thereby requires disclosure.
The definition of a SFI consists of three key components: Timeframe, Defined Threshold, and Institutional Responsibilities.
- First, the Timeframe is the period in which a financial interest exists and/or will exist and consists of the twelve (12) months prior to and the twelve (12) months after the time of disclosure.
- Second, the Defined Threshold consists of two monetary amounts, $5000 and $0.
The $5000 monetary threshold pertains to a $5000 aggregate amount, aggregated on an entity-by-entity basis for the entire Timeframe mentioned above, for:
1) income from and equity in a publicly traded entity (e.g. a pharmacologist owning $4500 in a publicly traded drug company’s stock and receiving $260 in dividends the twelve (12) months prior to disclosure and $300 in dividends in the twelve (2) months subsequent to disclosure from the stock);
2) income from a non-publicly traded entity (e.g. annual salary of $5000 from a private company owned by individual receiving the salary);
3) income from intellectual property rights and interests (e.g. $3500 per year in royalties from a patent); and
4) reimbursed or sponsored travel (e.g. $2600 trip on 6/1/2012 and $2500 trip on 3/1/2013, both sponsored by the same drug company, with a disclosure date of 1/1/2013)
The $0 monetary threshold pertains to a $0 aggregate amount, aggregated on an entity-by-entity basis (or source-by-source basis for intellectual property) for the entire Timeframe mentioned above, for:
1) equity in a non-publicly traded entity (e.g. 1% ownership interest in a small private business); and
2) income from managerial interests (e.g. an unpaid Member of the Board of Directors)
- Third, Institutional Responsibilities are University Personnel’s professional responsibilities on behalf of the University. A financial interest, which reasonably relates to University Personnel’s Institutional Responsibilities and meets the two other key components explained above, must be disclosed.
Most importantly, a SFI is not necessarily a financial conflict of interest; thus, when in doubt, disclose the financial interest.
Who is required to submit the financial interest disclosure forms to Office of Research?
The individuals who must disclose their SFIs differ depending on the type of sponsored project in which they are engaged: Public Health Service (PHS), which includes but is not limited to the NIH, versus Non-PHS sponsored projects. For PHS sponsored projects, the scope of individuals who must make disclosures is broad. All University Personnel, as defined in Drexel Policy, must submit disclosure forms to Office of Research. However, for Non-PHS sponsored projects, only those University Personnel designated as Senior/Key Personnel must submit disclosure forms.