Texas Tech University
Scholarly Messenger
Upcoming Changes to the Disclosure of Significant Business or Financial Interests that may Represent Conflicts of Interest Operating Policy

By Amy Baugh

The Faculty Senate Committee on Faculty Welfare and Status has approved changes to OP 70.37 as proposed by the Investigator Financial Disclosure Committee (IFDC). Changes to OP 70.37 were requested in order to streamline and clarify annual financial interest disclosure requirements for both Public Health Service (PHS) investigators (e.g. NIH) and for non-PHS investigators. Significant changes to the OP include:
  • OP 70.37, Disclosure of Significant Business or Financial Interests that may Represent Conflicts of Interest, will be reassigned as OP 74.17 when the revised OP is posted to the Texas Tech Operating Policies & Procedures site in late August 2014.
  • The AY 2014-2015 disclosure forms will be available strictly via a secure, eRaider-authenticated link, unless otherwise authorized by the associate vice president for research/responsible research (AVPR). All disclosure forms (those reporting no significant business or financial interests and those reporting significant business or financial interests) will be electronically forwarded to the unit head, then to the designated official, and finally to the AVPR.
  • The minimum monetary threshold for reporting a significant financial interest (SFI) for non-PHS investigators is lowered from $10,000 to $5,000.
  • Clarification that an SFI does not include mutual funds and other managed accounts, such as retirement accounts; however, investments in retirement accounts in which the investigator has control over which specific stocks or other equity interests are purchased, might trigger a need for disclosure if a particular holding directed by the investigator would reasonably appear to be affected by the specific research project.
  • The minimum threshold for travel disclosure is increased from any amount to an aggregate amount of $5000 from a single entity in the 12 months prior to disclosure. (Applies to PHS investigators).
  • Clarification of applicability of the OP to all TTU employees and other individuals planning to act as investigators.
  • Clarification that employees planning to act as PHS-funded investigators shall disclose any significant business or financial interest that would reasonably appear to be related to the investigator’s institutional responsibilities.
  • If a potential or actual conflict of interest is identified, a signed Financial Conflict of Interest management plan must be in place prior to expenditure of funds under the award.
  • Clarification of potential sanctions to include suspension of award funds and withholding of salary.
A memo will be distributed to faculty when the interactive online application is accepting AY 2014-2015 financial disclosures.

For more information contact, Amy Baugh, Financial Disclosure Administrator, Office of the Vice President for Research, (806) 834-2139, or Ralph Viator, Clark & Lois Webster Professor, Area of Accounting, Rawls College of Business, and IFDC Chair.

Amy Baugh is the financial disclosure administrator in the Office of the Vice President for Research.