Financial Disclosure Policy
FINANCIAL DISCLOSURE POLICY FOR INVESTIGATORS AND ALL SENIOR PERSONNEL FUNDED BY FEDERAL GRANTS
The federal government requires as part of the routine certification process that the College establish and administer a financial disclosure policy for investigators. This is designed to ensure appropriate management of actual or potential conflicts of interest. The Bates College policy fulfills the requirements of grantee institutions as put forth in the National Institutes of Health’s guidelines (see http://grants.nih.gov/grants/policy/coi/index.htm) and the National Science Foundation’s conflict of interest policies (seehttp://www.nsf.gov/pubs/policydocs/pappguide/nsf08_1/aag_4.jsp#IVA).
For every proposal submitted to a federal agency, each investigator and all senior personnel must submit a Conflict of Interest form (see https://www.bates.edu/grants/files/2016/08/NewDisclosures.docx) to disclose to the dean of the faculty (the designated representative) all significant interests, including those of the investigator’s spouse, partner, and dependent children (a) that would reasonably appear to be affected by the research or educational activities funded by or proposed for funding a federal agency, or (b) in any entity whose financial interests would reasonably appear to be affected by the activities of the grant.
• All grant-funded senior personnel are required to disclose to a responsible representative of the institution all significant interests (including those of the investigator’s spouse, partner, and dependent children) (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by the federal government; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities.
• Significant financial interest means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees, honoraria); equity interest (e.g., stocks, stock options, other ownership interests); and intellectual property rights (e.g., patents, copyrights, and royalties from such rights).
• The term does not include: a) salary, royalties, or other remuneration from the applicant institution; b) any ownership interests in the institution, if the institution is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program; c) income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; d) income from service on advisory committees or review panels for public or nonprofit entities; e) any equity interest that, when aggregated for the investigator and the investigator’s spouse, partner, and dependent children does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or f) salary, royalties, or other payments that, when aggregated for the investigator and the investigator’s spouse, partner, and dependent children, are not expected to exceed $10,000 during the twelve-month period.
• Investigators must provide all required financial disclosures at the time the proposal is submitted, and must update those financial disclosures during the period of the award, either on an annual basis, or as new reportable significant financial interests are obtained.
• An institution must designate one or more persons to review financial disclosures, determine whether a conflict of interest exists, and determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce, or eliminate such conflict or interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of federally funded research or educational activities.
• The following are examples of conditions or restrictions that might be imposed to manage, reduce, or eliminate conflicts of interest: a) public disclosure of significant financial interests; b) monitoring of research by independent reviewers; c) modification of the research plan; d) disqualification from participation in the portion of the federally funded research that would be affected by significant financial interests; e) divestiture of significant financial interests; or f)
severance of relationships that create conflicts.
• If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.
• The College is required to have adequate enforcement mechanisms, and provide for sanctions where appropriate.
• The College is required to keep the federal granting agency appropriately informed if it is determined that the College is unable to satisfactorily manage a conflict of interest.
• The College must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any federal action involving those records, whichever is longer.