Overview The federal regulations require that investigators disclose certain financial information to the university. Rutgers policy sets October 1 as the annual deadline, with initial disclosures due October 1, 2012.
Please note that disclosure does NOT imply that the investigator is conflicted; relationships with industry and the commercialization of technology are encouraged at Rutgers University. Such activities need to be disclosed and conducted in such a way that financial interests do not affect the objective conduct of the research.
The disclosures will be reviewed by a faculty committee, and when there is the need, perceived or actual conflicts will be reduced, managed or mitigated.
Education in the federal conflict of interest regulations is required; a convenient online option is available.
Effective Date: August 24, 2012
Who must disclose? Disclosure is required by Investigators. An Investigator, according to the federal regulations, is anyone involved in the design, conduct or reporting of research. The federal regulations also take family financial interests into consideration – certain financial interests held by the Investigator's spouse or domestic partner or dependent children must also be disclosed.
Investigators who are currently funded by PHS agencies will need to complete disclosure forms, as well as investigators who will apply for PHS funding.
What information is disclosed? Significant financial interests (SFI) related to the Investigator's institutional responsibilities must be disclosed.
SFI's are more deeply defined in the Rutgers policy and disclosure forms found at http://vpr.rutgers.edu/pro but in general SFI's include remuneration from entities outside Rutgers that in the previous 12 months from the date of disclosure, and when aggregated, exceed $5,000, and any equity (no threshold). Royalties from outside entities that do not involve Rutgers must also be disclosed. (Therefore if Rutgers negotiated the licensing agreement, those royalties need not be disclosed.)
"Investigator's institutional responsibilities" means an Investigator's professional responsibilities on behalf of the institution, including but not limited to research, research consultation, teaching, professional
practice, institutional committee memberships, and service on panels such as the IRB. Again, this is more deeply defined in the Rutgers policy.
Specific types of travel must be disclosed; grant-funded travel is NOT included. In general, travel that is sponsored by a state agency, an institution of higher education, an academic health center or research institute need NOT be disclosed. Travel that does not fall under the previous exceptions and is reimbursed or sponsored (ie the traveler may not know the cost of the travel) related to one's institutional responsibilities does need to be disclosed.
Timing of Disclosures Disclosures must be made no later than the time of application for PHS funding, utilizing the online forms at http://vpr.rutgers.edu/pro. For investigators working on projects with active PHS funding, initial disclosures under this new policy must be completed by October 1, 2012, and then annually by each October 1.
Required Education on the Federal Conflict of Interest Regulations NIH provides online training here: http://grants.nih.gov/grants/policy/coi/tutorial2011/fcoi.htm
Training must take place prior to engaging in the PHS-funded research, according to the federal regulations.
Please be sure to print out a certificate of completion at the end of the training session, and to save a pdf file of the certificate.
For More Details: Please go to http://vpr.rutgers.edu/pro for the Rutgers policy and disclosure forms.
- NIH has posted an information-rich website here http://grants1.nih.gov/grants/policy/coi/index.htm that includes FAQ's, access to the federal regulations, and case studies.
- Information will continue to be added to http://vpr.rutgers.edu/pro where the policy and disclosure forms can be found now, as well as information about required training.
- Please direct questions to firstname.lastname@example.org