Frequently asked Questions

For purposes of financial conflict of interest regulations, any individual acting as a “project director, principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research” is an investigator and must satisfy the disclosure requirements.

Any University employee, regardless of title or position, who has the ability to make independent decisions related to the design, conduct, or reporting of University research. This does not include individuals who perform only incidental or isolated tasks related to a University research project. Since title and position are not indications of who is an “investigator,” students and post-docs likely meet this definition. Please note, in nearly all situations when an individual is listed as senior or key personnel on a proposal or award they are considered an investigator for purposes of submitting a financial disclosure statement.

Yes.

Investigators are required to disclose their SFI: 

1. within 30 days of the investigator’s initial employment date;
2. annually, based on the prior disclosure date(s);
3. within 30 days after acquiring a new SFI requiring disclosure; and
4. for those Investigators participating in Public Health Service (PHS)-funded research, not later than the application date for PHS-funded research.

Investigators are required to disclose any Significant Financial Interest (SFI) to the University. 

A financial interest, including but not limited to one or more of the following interests of the investigator (and those of the investigator’s covered family members) that reasonably appears to be related to the investigator’s institutional responsibilities:

1. With regard to any publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated for the investigator and members of his/her immediate family, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;
2. With regard to any non-publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated for the investigator and members of his/her immediate family, exceeds $5,000, or when the investigator (or the investigator’s immediate family member) holds any equity interest (e.g., stock, stock option, or other ownership interest);
3. Intellectual property and royalty interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests;
4. The occurrence of any reimbursed or sponsored travel related to their institutional responsibilities (including that which is paid on behalf of the investigator but not reimbursed to the investigator so that the exact monetary value may not be readily available); provided, however, that this does not include travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;.
5. Gifts, when the value of a single gift received by the investigator or a covered family member in the preceding 12 months exceeds $250, or when the aggregated value of multiple gifts received from a single entity within the preceding 12 months exceeds $250, excluding gifts received from a covered family member; or
6. Any fiduciary position held by an investigator or a covered family member in a for-profit or nonprofit entity in the preceding 12 months, including a position as a member of the board of directors, an officer, or other executive or management position, for which the investigator or covered family member received any form of remuneration or reimbursement for expenses.

SFI does NOT include:

1. Salary, royalties, or other remuneration paid by a member to the investigator if the investigator is currently employed or otherwise appointed by the member;
2. Intellectual property rights assigned to the system or its member and agreements to share in royalties related to such rights;
3. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles;
4. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;
5. Income from service on advisory committees or review panels for a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education;
6. Travel reimbursed or sponsored by a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

Investigators must disclose those SFIs that “reasonably appear to be related” to the investigator’s institutional responsibilities. Each Investigator can make a reasonable, good-faith determination about whether or not any given SFI is related to their institutional responsibilities, rather than simply disclosing everything. They need to ask whether, to the best of their knowledge, the research or other institutional responsibilities that they have could affect the value of the financial interest or could have a financial impact on the entity in which they hold the financial interest (even if only in the future). Generally, however, 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 expertise in the field. In addition, if an entity in which an SFI is held is involved in the same research project (e.g. , via a subcontract), then it is always related to the investigator’s institutional responsibilities.

Some examples include:

1. You are a paid consultant to COI, Inc., which also subcontracts a portion of a research project to your lab at the University. 
2. You are a paid consultant to COI, Inc., and you subcontract a portion of your research project back to COI, Inc.
3. You are a paid speaker for COI, Inc., and also the PI of a research project funded by COI, Inc.
4. COI, Inc. has paid for your travel. You also conduct research at the University that is likely to develop intellectual property that you know would be of interest to COI, Inc.
5. You own stock in COI, Inc. and COI, Inc. provides cost-sharing on an award in your lab at Texas A&M University.

Yes. Even if you do not have an SFI to disclose, you must still complete the Financial Disclosure Statement. 

Income from a US federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education, is not included in SFI and does not need to be disclosed.

However, honoraria or payments from foreign institutions MUST be disclosed.

Income from a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education, is not included in SFI and does not need to be disclosed.

However, income from any foreign government agency MUST be disclosed. 

Yes. Federal regulations require the disclosure of income and travel from non-profit organizations.

Yes. Professional societies are non-profit organizations, and travel and income from them is required to be disclosed.

This 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.

No. Royalties or other remuneration received from the A&M System is excluded from the definition of SFI and does not need to be disclosed.

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 need to be disclosed. If you own other investments, such as stock in an individual corporation, even if held in a retirement account, and those investments can be bought or sold at your discretion, you will need to evaluate each such investment in order to determine whether it is reasonably related to your institutional responsibilities.

The lunch would be considered a gift and could be disclosed if, in aggregate with other compensation or any equity in the company, you exceed the $5,000 threshold for the past 12 months. However, if the lunch (gift) is the only financial interest you have in the company, then it would not need to be disclosed. Please note that this is not a travel expense as the lunch occurred locally. Also, if you receive meals while traveling, you would not be required to disclose them specifically, but could be included in the total expense of the trip if you know the expense.

Income from service as an expert witness should be disclosed if it relates to your 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 you should disclose your expert witness compensation.

The occurrence of any reimbursed or sponsored travel related to the investigator’s institutional responsibilities must be disclosed, UNLESS travel expenses are reimbursed or sponsored by a federal, state, or local government agency, or an institution of higher education as defined by 20 U.S.C. §1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. 

Within 30 days of the end of any trip, investigators must update their disclosures with the following information:  travel purpose, destination, duration, and sponsor. 

The revised federal regulation does not provide a minimum threshold for the disclosure of reimbursed or sponsored travel. Cost is an optional entry, if you have the information available, but for many investigators, travel expenses are paid directly (sponsored), preventing knowledge of the actual amount paid. 

You must disclose the SFI immediately. The disclosure will be reviewed to determine if a financial conflict of interest exists, and if so, a management plan will be implemented to ensure the objectivity of the research going forward.