What Do I Disclose?

• All research or research activities in which the investigator is engaged in;
• Any financial interest held by the investigator or a covered family member of the investigator;
• The total amount of salary or other payments received in the preceding 12 months, in rounded, whole dollar amounts;
• A description and the value of any equity interest (e.g., stock, stock options, or other ownership interest or entitlement to such an interest) in rounded, whole dollar amounts by reference to public prices or other reasonable measures of fair market value;
• A description and the value of any intellectual property or royalty interests in rounded, whole dollar amounts;
• The source of the SFI, including the source’s name and principal address; and
• For each occurrence of reimbursed or sponsored travel, the purpose of the trip, the identity of the sponsor/organizer, the destination and the duration of the trip. Each member, at its discretion, may require an investigator to disclose additional information in order to determine whether the travel at issue constitutes a FCOI.

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:

(a) 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;

(b) 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) holds any equity interest (e.g., stock, stock option, or other ownership interest);

(c) Intellectual property and royalty interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests;

(d) 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;

(e) 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

(f) 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:

(a) Salary, royalties, or other remuneration paid by a member to the investigator if the investigator is currently employed or otherwise appointed by the member;

(b) Intellectual property rights assigned to the TAMU system or its members and agreements to share in royalties related to such rights;

(c) 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;

(d) 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;

(e) 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;

(f) 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 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 a 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-Corpus Christi.