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Financial Conflict of Interest in Research

WHO MUST DISCLOSE

Any University employee, regardless of title or position, who has the ability to make significant independent decisions related to the design, conduct, or reporting of University research or research activities related to their work on funded sponsored research activities.

Why is there a disclosure requirement?

State and Federal regulations require Texas A&M-San Antonio to have policies in place to promote objectivity in research for which Public Health Service (PHS) Funding is sought (42 CFR Part 50 Subpart F), and to address state laws prohibiting state employees from having an interest that is in conflict with their official duties.

Who needs to disclose Financial Conflicts of Interest?

Individuals who ho are responsible for the design, conduct, or reporting of research (e.g., principal investigator, co-principal investigator, project director, or student who receive compensation in the form of scholarship, salary, or tuition reimbursement).

Any individual acting as a project director, or 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 in this document. This does not include individuals who perform only incidental or isolated tasks related to a university research project. 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.

Do you need to complete the COI training and COI disclosure if you conduct social, behavioral, and/or educational research, instead of biomedical research?

Yes. COI training and disclosure requirements apply to all individuals responsible for the design, conduct, or reporting of research, regardless of the funding source or field of study.

Do Post-Docs and Graduate Students need to disclose?

Yes, if they meet the definition of “investigator” above. Since title and position are not indications of who is an "investigator," it is possible for students and post-docs to meet this definition.

Who is a “Covered Family Member”?

A “Covered Family Member” includes a:

  1. Spouse;
  2. Dependent child or stepchild or other dependent, for purposes of determining federal income tax liability during the period covered by the disclosure statement, or a
  3. Related or non-related, unmarried adult who resides in the same household as the covered individual and with whom the covered individual is financially interdependent as evidenced, for example, by the maintenance of a joint bank account, mortgage, or investments.

If the covered individual is in doubt about whether an individual is a covered family member, the covered individual should resolve the doubt in favor of disclosure.