| 10 Things to Know about Annual Disclosure of Financial Interests
by Amy Baugh
Federal regulations require that institutions have policies and procedures in place to ensure that employees disclose any significant financial interests that may represent an actual or potential conflict of interest in relationship to externally sponsored projects. Financial disclosure serves to protect the credibility and the integrity of the university's faculty and staff, as well as the institution, so that public trust and confidence in its sponsored activities are not compromised. Amy Baugh, Financial Disclosure Administrator, answers questions regarding the annual financial disclosure requirement for all externally funded Investigators.
Do I need to disclose?
All Investigators who have externally sponsored projects MUST submit a financial interest disclosure form by October 1 each year and within 30 days of acquiring a new significant financial interest.
- What's the easiest way to get this done?
The most convenient way for Investigators to submit electronic annual disclosure forms is to visit this site.For more information regarding financial disclosure and to access PDF disclosure forms, please visit this site.
- Who's considered an Investigator?
"Investigator" means the principal investigator, co-principal investigators, and any other person at TTU or its subgrantees, contractors, or collaborators who is responsible for the design, conduct, or reporting of research or educational activities that are funded or proposed for funding by an external entity.
- Why are there two different disclosure forms: PHS-specific and non PHS/all other externally funded investigators?
Investigators who have pending or current Public Health Service funding (National Institutes of Health and other PHS funding agencies) must complete the PHS-specific disclosure form. Completing the PHS-specific disclosure will satisfy all TTU disclosure requirements; completing both the general disclosure form and the PHS-specific disclosure form is not necessary. Non-PHS funded investigators may complete either form.
- What can I expect when I enter the electronic disclosure system?
The non-Public Health Service (PHS) disclosure document consists of six (6) initial questions. The PHS-specific disclosure document has 11 initial questions. The Supplemental Detailed Disclosure of Significant Business or Financial Interest form must also be completed if the answer to any of the initial questions is positive (will, did or do).
- How long will this take?
The mean duration of time taken to complete the electronic disclosure questionnaire is 8 minutes 23 seconds (n=572).
- What's the difference between financial disclosure and financial conflict of interest?
Financial disclosure refers to providing information regarding the existence of significant business and financial interests. A financial conflict of interest is a significant business and financial interest that could significantly or perceivably affect the design, conduct or reporting of research. Financial disclosure is the tool utilized to determine whether or not a financial conflict of interest exists. Financial conflicts of interest are determined by the AVPR (Integrity) when reviewing annual financial disclosures.
- Are you saying that I have a conflict of interest?
Not all significant business and financial interests are conflicts of interest. In fact, most significant business and financial interests that are determined to be conflicts of interest are perceived or potential conflicts of interest rather than actual conflicts of interest. Perceived, potential and actual conflicts of interest will be managed, reduced or eliminated by implementing investigator management plans developed in concert by the AVPR (Integrity) and the investigator.
- I don't have any relationships with outside entities. Do I still have to disclose?
Investigators who have no outside financial interests are still required to submit a financial interest disclosure form. Investigators will select the appropriate answers to the statements on the form and submit the form to the Financial Disclosure Administrator.
- Is the outside employment request form the same as the financial disclosure form?
The outside employment request form (OP 32.07) is a separate process facilitated through the Provost’s Office.
- Hey, you said there were 10 things to know. Why are there now 11 things to know?
Because I thank you very much for completing and submitting your annual financial disclosure forms, and I invite you to contact me with any additional questions or concerns. Thank you again for your time and cooperation!
Amy Baugh is the financial disclosure administrator in the Office of the Vice President for Research. You can reach her by email
or contact her at 806-834-2139.