The University of Texas at Dallas (UTD) has implemented Policy Memorandum 95-III.27-69 Research Investigator Financial Disclosure ("Policy"), to manage significant financial interests and conflict of interest situations as they arise from research conducted at and by UTD faculty and research staff. The Policy and the accompanying procedures insure compliance with state and federal laws/regulations, and manage specific conflict of interest situations deemed important at UTD.
The Research Investigator Financial Disclosure Annual Certification of Compliance must be completed by all UT Dallas faculty, principal investigators and co-principal investigators on external grants and contracts, and individuals who have a significant financial interest in an entity in which the university conducts research, development, or scholarship related business.
The Policy provides responsibility and authority for initial review of conflict of interest situations with the Office of Research Integrity, within the Office of the Vice President for Research, subject to oversight by a Conflict of Interest Management Plan Review Panel administered under the auspices of the Research Integrity Committee.
The National Science Foundation (NSF) and the Public Health Service (PHS) have requirements for disclosure of Significant Financial Interests for all persons responsible for the design, conduct, or reporting of funded research, or research proposed for such funding. Therefore, any person responsible for the design, conduct, or reporting of research with a significant financial interest, including graduate students and non-academic employees, that 1) would reasonably appear to be affected by the research and / or (2) in entities whose financial interests would reasonably appear to be affected by the research must disclose those interests at the time the proposal is submitted to the NSF / PHS or as soon as a significant financial interest arises after submission of the proposal to the NSF / PHS while it is still being reviewed for possible funding or after funding begins.
Disclosure is required for each situation when the research investigator has a significant financial interest that is related to his or her funded or proposed research projects. Conflicts of interest must be disclosed prior to the submission of proposals for sponsored projects where the principal investigator and any other person who is responsible for the design, conduct, or reporting of the project holds a Significant Financial Interest regardless of the source of funding, or prior to the authorization for start of the sponsored project in the event that funding results from other than a written proposal.
Faculty and all other research investigators are responsible for disclosing to the Office of Research Integrity a conflict of interest as soon as he or she is aware of the conflict. Such disclosure should be given in writing, using the Research Investigator Financial Disclosure. The high degree of professional autonomy granted to research investigators carries with it the professional responsibility for disclosing a personal interest that could reasonably be viewed by others as biasing the investigator's professional judgment. The investigator's personal belief that the competing personal interest would not actually bias his or her actions should not be a factor in the investigator's decision whether to disclose the interest under the Policy. The Policy supports openness and erring on the side of disclosure.
A conflict of interest exists when a research investigator's financial interests or other opportunities for tangible personal benefit may compromise, or reasonably appear to compromise, the design, conduct, or reporting of funded or proposed research at the University. The presence of a conflict of interest does not mean that there has been or will be a misdeed; however, failure to disclose a conflict of interest may properly be viewed as a misdeed. An unreported conflict of interest may result from a failure to disclose a conflict of interest or, even more seriously, a false certification of the absence of a conflict of interest. Failure to report or providing a false certification of a conflict of interest constitutes noncompliance with the Policy and may be cause for disciplinary action.
The following interests are considered to be significant financial interests and, subject to the exclusions provided below, an investigator’s disclosure statement must include the following information in regard to the investigator and his/her Covered Family Members, but only in regard to interests that reasonably appear to be related to the individual’s institutional responsibilities:
(1) PAYMENTS RECEIVED FROM OR EQUITY INTEREST IN A PUBLICLY TRADED ENTITY: the total amount and source of payments received in the preceding twelve months from a publicly traded entity and the value of any equity interest held in the entity on the date of disclosure that, when aggregated, exceed $5,000, including:
(A) as to payments received:
(i) salary; and
(ii) any payment for services other than salary, such as consulting fees, honoraria, or paid authorship; and
(B) as to equity interests held, any stock, stock options, or other ownership interest or entitlement to such an interest, valued by reference to public prices or other reasonable measures of fair market value;
(2) PAYMENTS RECEIVED FROM A NON-PUBLICLY TRADED ENTITY OR EQUITY INTEREST IN A NON-PUBLICLY TRADED ENTITY:
(A) the total amount and source of payments received in the preceding twelve months from an entity that is not publicly traded that, when aggregated, exceed $5,000, including:
(i) salary; and
(ii) any payment for services other than salary, such as consulting fees, honoraria, or paid authorship; and
(B) a description of any equity interest held in an entity that is not publicly traded, including any stock, stock options, or other ownership interests or entitlement to such an interest;
(3) INTELLECTUAL PROPERTY AND ROYALTIES:
(A) a description of intellectual property rights held and any agreements to share in royalties related to those rights; and
(B) the amount and source of royalty income that the investigator or covered family member received or had the right to receive in the preceding twelve months;
(4) TRAVEL: reimbursed or sponsored travel in the preceding 12 months, including the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration;
(5) GIFTS: the value and source of a single gift that the investigator received in the preceding twelve months that exceeds $250 in value, or multiple gifts from a single entity that in the aggregate exceed $250 in value, other than gifts from a covered family member; and
(6) FIDUCIARY POSITIONS: a fiduciary position the investigator held in a for- profit or nonprofit entity in the preceding twelve months, including a position as a member of the board of directors, an officer, or other executive or management position, for which the individual received any form of remuneration or reimbursement for expenses, and the name and principal address of the entity.
The following interests are not significant financial interests and need not be disclosed on the disclosure statement:
(1) salary, royalties, or other remuneration paid by the University to the covered individual, if the covered individual is currently employed or otherwise appointed by the University;
(2) income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government, 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 affiliated with an institution of higher education;
(3) income from service on an advisory committee or review panel for a federal, state, or local government, 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 affiliated with an institution of higher education;
(4) income from investment vehicles, such as mutual funds or retirement accounts, as long as the covered individual does not directly control the investment decisions made in those vehicles; or
(5) travel reimbursed or sponsored by a federal, state, or local government agency, 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.
In making disclosures under this section, the investigator shall disclose the value of a significant financial interest within the following ranges:
(1) $0 - $4,999;
(2) $5,000 - $9,999;
(3) $10,000 - $19,999;
(4) amounts between $20,000 - $100,000 by increments of $20,000; or
(5) amounts above $100,000 by increments of $50,000.
When describing a source, the investigator shall provide the name and principal address for the source. The investigator shall distinguish among information pertaining to the investigator and covered family members whose financial interests and activities are also disclosed by the investigator.
The Research Integrity Committee, with assistance from the Office of Research Integrity, assumes a leadership role for reviewing reported conflicts in coordination with the dean of the school of the research investigator and the Office of the Provost, unless either office also has a conflict of interest related to the situation. Conflict of interest situations are reviewed independently by a Conflict of Interest Management Plan Review Panel, which makes recommendations as to how the potential conflict can be managed, reduced, or eliminated.
