TEST COI FAQ

COI FAQs

Disclosure FAQs

  1. What must be disclosed?
  2. Do adjuncts, post-docs, and staff need tosubmit an SFI disclosure?
  3. Do I have to disclose travel?
  4. What is an outside organization?
  5. Do I need to disclose salary paid to me by George Mason University as an Investigator?
  6. How do I submit a disclosure?
  7. Must Investigators disclose interests in mutual funds?
  8. Must investigators disclose stock and stock options?
  9. What is the timeframe for disclosure if I obtain a new Significant Financial Interest (SFI) related to my university responsibilities?

General Questions

  1. When will my disclosure be reviewed?
  2. Which agencies have adopted the PHS regulations?
  3. What if I disagree with the requirements of the Conflict of Interest Committee or Vice President for Research and Economic Development under policy 4010?
  4. What if the President does not approve my waiver request under policy 4001?
  5. Will my disclosure be maintained confidentially?

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1. What must be disclosed?

All investigators applying for federal funding must disclose personal Significant Financial Interests (SFIs) and those of the investigators spouse and dependent children related to institutional responsibilities. SFIs include:

  • (i) With regard to any publicly traded entity, a SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure certification and the value of any equity interest in the entity as of the date of disclosure certification, when aggregated, 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;
  • (ii) With regard to any non-publicly traded entity, a SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the investigator (and/or the investigator’s spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
  • (iii) Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests. Additionally, investigators applying for PHS funding must disclose the occurrence of travel paid by an outside organization that is related to their institutional responsibilities.

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2. Do adjuncts, post-docs, and staff need to submit an SFI disclosure?

Only if they are an Investigator. An Investigator is the Project Director/Principal Investigator and any other person, regardless of title or position, who is independently responsible for the design, conduct, or reporting of federally-funded research.

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3. Do I have to disclose travel?

Only PHS funded investigators (and investigators funded by agencies/organizations that have adopted PHS rules) are required to disclose travel. For this group of investigators all travel must be disclosed.

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4. What is an outside organization?

Any non-GMU organization with the exception of a Federal, state, or local government agency, an Institution of higher education as defined at 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.

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5. Do I need to disclose salary paid to me by George Mason University as an Investigator?

No. Salary, royalties, or other remuneration from George Mason University does not need to be disclosed.

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6. How do I submit a disclosure?

You log in to the COI Disclosure Site using your Mason ID and password, complete the forms, and press submit.

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7. Must Investigators disclose interests in mutual funds?

Investigators are not required to disclose 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.

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8. Must investigators disclose stock and stock options?

Yes. Investigators must disclose stock and stock option assets if they meet the definition of a SFI.

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9. What is the timeframe for disclosure if I obtain a new Significant Financial Interest (SFI) related to my university responsibilities?

You must disclose new SFIs within 30 days.

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General Questions

1. When will my disclosure be reviewed?

The Conflict of Interest Committee meets monthly to review disclosures. Certain categories of disclosures may be reviewed more quickly by a committee member through an expedited review procedure.

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2. Which agencies have adopted the PHS regulations?

The following is a list of PHS agencies and other sponsors that have adopted the PHS regulations:

  • Administration on Aging (AoA)
  • Administration for Children and Families (ACF)
  • Agency for Healthcare Research & Quality (AHRQ)
  • Agency for Toxic Substances & Disease Registry (ATSDR)
  • Alliance for Lupus Research (ALR)
  • American Cancer Society (ACS)
  • American Heart Association (AHA)
  • Arthritis Foundation (AF)
  • California Breast Cancer Research Program (CBCRP)
  • California HIV/AIDS Research Program (CHRP)
  • Centers for Disease Control & Prevention (CDC)
  • Food and Drug Administration (FDA)
  • Health Resources & Services Administration (HRSA)
  • Indian Health Service (IHS)
  • Juvenile Diabetes Research Foundation (JDRF)
  • Lupus Foundation of America (LFA)
  • National Institutes of Health (NIH)
  • Substance Abuse & Mental Health Services Administration
    (SAMHSA)
  • Susan G. Komen for the Cure

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3. What if I disagree with the requirements of the Conflict of Interest Committee or Vice President for Research and Economic Development under policy 4010?

An appeal may be made to the Provost’s office following the procedures outlined in policy 4010.

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4. What if the President does not approve my waiver request under policy 4001?

The university will not enter a contract with the company in which you have > $10,000 income or >3% ownership unless the President accepts and approves your waiver request.

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5. Will my disclosure be maintained confidentially?

Initial disclosures are confidential and considered part of the investigator’s personnel file. However, both the federal government and Virginia have freedom of information provisions.  Under these provisions certain information must be released. This includes all waiver requests under Virginia law and certain information for PHS funded investigators including: investigator’s name, title, and role with respect to the research project; name of the entity in which the SFI is held; nature of the SFI; and approximate dollar value of the SFI.

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