Significant Financial Interest Disclosure Guidelines and Forms


Who must disclose?

The UM Objectivity in Research Policy requires that Investigators disclose any significant financial interest are related to institutional responsibilities (i.e., teaching, research, administrative, or clinical duties). Investigator is defined in the policy as faculty, staff or students serving as Project Directors, Principal Investigators, and any member of the research team who is responsible for the design, conduct or reporting of externally sponsored research, including collaborators, consultants, subrecipients, contractors, and consortium participants. External sponsor means any granting agency outside the University, including both governmental and non-governmental sponsors.

What must be disclosed?

1.  Significant Financial Interests - financial interests, received by an Investigator, and/or their spouse or dependent children, in the past 12 months, consisting of one or more of the following that is related to Institutional Responsibilities.

2.  Participation in a Foreign Government Talent Recruitment Program

 A "Foreign Government Talent Recruitment Program" is a program sponsored by some foreign governments or affiliates with distinguishing features that generally include compensation and recruitment. Some examples can be found here.

3.  Other Support

"Other Support" includes all outside resources (from foreign and domestic entities) directly supporting your research endeavors, regardless of whether or not they have monetary value. This includes (but is not limited to):

  1. Titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
  2. Research resources such as personnel, lab space, scientific materials, or high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).

When must disclosure be done?

All Investigators must disclose Significant Financial Interests to the Director of Research Integrity and Compliance at least annually, but no later than the following:

  1. Prior to first submission of a proposal.
  2. Prior to participating in an active, funded research project.
  3. Within thirty (30) days of acquiring any new Significant Financial Interest(s).

How are disclosures made?

Disclosures should be made through the Qualtrics survey found here.  If you have difficulty accessing the survey or have additional entities to report, a fillable form is available.

How is disclosure information used?

The Director of Research Integrity and Compliance will conduct a preliminary review of all Significant Financial Interest disclosures 1) to determine if Investigators’ disclosure information is sufficiently complete for review or whether the Investigator must provide additional information or clarification and 2) to make an initial assessment on the impact of a given Significant Financial Interest on the Research and either determine the Significant Financial Interest does not represent a real or perceived conflict or refer the matter to the Conflict of Interest Committee (COIC) for review and management.

To the extent permitted by law, including the Mississippi Public Records Act, all records of financial interest submitted by an Investigator shall be made available only to the Conflict of Interest Committee and to others on a “need to know” basis with clear understanding of the confidentiality of the information. Records will be destroyed once the record retention period expires.

As required by federal regulations at 42 CFR 50.605(b) ORSP shall send report a Financial Conflict of Interest (any Significant Financial Interest that reasonably could or appear to significantly affect the design, conduct, or reporting of research)to any funding agency that has adopted PHS regulations, including the following:

  1. US Public Health Service Agencies including:
    •  ‚ÄčNIH
    • CDC
    • HRSA
    • FDA
    • AACF
    • AHRQ
    • ATSDR
    • IHS
    • SAMHSA
  2. Non-PHS Agencies (subject to change, must be verified in award terms and conditions) including:
    • Alliance for Lupus Research
    • Alpha-1 Foundation
    • Alzheimer's Drug Discovery Foundation 
    • American Asthma Foundation
    • American Heart Associatiom
    • American Cancer Society
    • American Lung Association
    • Arthritis Foundation
    • CurePSP
    • Johnson & Johnson
    • Lupus Foundation of America
    • PCORI
    • Susan G. Komen Foundation
    • Juvenile Diabetes Research Foundation
  3. Federal sponsors with regulations similar to PHS or that follow a component of PHS regulations:
    • Department of Energy
    • National Aeronautics and Space Administration (NASA)

Guidance on Developing Your Conflict of Interest Management Plan