Disclosures
Under UToledo’s Financial Conflict of Interest Policy (3364‑70‑01), all faculty, staff, and students who are involved in the design, conduct, or reporting of sponsored activities (i.e., “investigators”) are required to disclose their relevant external financial interests. This does not include unfunded exempt research.
Financial Conflict of Interest (FCOI) disclosures are required prior to engaging in a sponsored project and must be updated annually or whenever new significant financial interests arise, in order to ensure compliance with federal regulations and maintain objectivity in research.
A disclosure does not necessarily mean there is a COI; final determinations are made by the COI Committee.
What to Disclose
Common activities to disclose include Compensation, equity, intellectual property rights, sponsorship (not through UToledo), royalties, affiliations or appointments with foreign entitites, participation in foreign talent programs, or other financial interests that are related to the researcher's institutional roles and activities.
Examples of Disclosures
- I am an officer, director, board member, or make decisions for an outside organization.
- Hold a financial or fiduciary interest in an outside organization that is seeking
to do or doing business with UToledo.
- Fiduciary example: Serving as an upaid board member for a non-profit organization that receives University funding.
- I am a paid consultant with an outside organization.
- Serving on a company's Scientific Advisory Board or providing expert testimony.
- I am affiliated or hold an appointment with a foreign entity.
- Participating in a foreign talent program, holding an adjunct position, honorary, visiting, or other roles with a foreign organization.
- I receive support, outside of UToledo, from a foreign government, foreign academic institutions or other foreign organization, including laboratory space or funding.
- I am traveling and someone, other than UToledo, reimburses you for your travel.
- A company paid for my flights, meals, and hotel to attend a conference.
- I receive personal payment from an organization, other than UToledo.
- I earn royalities from licensed technologies from a previous institution.
- I am an investor or stockholder in a company (even if the company is not worth anything).
- I am conducting research outside of UToledo (not administered through the Office of
Research).
- Receiving funding, serving as the principal investigator (PI), key personnel or consultant for research projects outside of UToledo.
- I am serving as a National PI of a clinical trial in your personal capacity (not administered through the Office of Research).
- Have family members who participates in any of the above scenarios.
- Family member means immediate family, including the investigator’s spouse or domestic partner, and dependent children or step-children.
What Not to Disclose
- Any type of funding that is received through UToledo.
- Unfunded exempt research.
- Income from investments that are not directly controlled by the researcher, i.e., retirement accounts and mutual funds.
- Relationships with outside organizations that are unrelated to the researcher's employment or research interests and the organization is not seeking to do business with UToledo.
Examples of Disclosures that Can Excluded
- I recently served on an NIH review panel.
- Review panel activities sponsored by U.S. federal agencies are not reportable.
- I gave a workshop at another university and they paid a small honorarium and paid
for some of my travel costs.
- Seminars and lectures to U.S. institutions of higher education are not reportable. (However, seminars and lectures to non-profit agencies are reportable.)
- I gave a workshop to SwRI and have been compensated.
- Speaking engagements at research institutes affiliated with U.S. universities are not reportable. (However, if you are a SwRI employee, you must report your employment there.)
- Retirement accounts.
- Do not disclose mutual funds or retirement accounts where you do not directly control the investment decisions. You do not need to monitor and disclose daily changes in the value of stock.
- I work as a high school basketball coach and receive payment for this work.
- Do not disclose gifts, employment or other payments unrelated and dissimilar to your job at UToledo.
How to Disclose
Here are step-by-step instructions to complete or download the financial conflict of interest disclosure requirements in InfoEd.