Q. I previously submitted my disclosure using the Rutgers Online Disclosure of Financial Conflict of Interest (fCoI) (fcoi.rutgers.edu). Do I still have to submit a new disclosure in eCOI?
Q. Who will have access to my disclosure information?
A. Your CoI disclosure is maintained as confidential information. Only CoI staff and the CoI Committee will have access to your information.
Q. What is a Significant Financial Interest (SFI)?
A: A Significant Financial Interest (SFI) is defined as one of the following:
A financial or other personal interests of the investigator, his or her spouse, domestic partner, children, parent or siblings that reasonably appears to be related to the Investigator's institutional responsibilities:
Service as an officer, director or in any other fiduciary role for a financially interested company, whether or not remuneration is received for such service;
Intellectual property rights (e.g., pending patent applications, patents, licenses, material transfer agreements, copyrights and royalties of any amount from such rights, including those royalties distributed by the University);
With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes compensation, royalties, consulting fees, honoraria, gifts or other emoluments, bonuses, enrollment incentives or milestone payments, and “in kind” compensation or entitlement to same made directly or indirectly to the investigator by a financially interested company (or entitlement to the same), whether for consulting, lecturing, travel (including reimbursed travel or sponsored travel), service on an advisory board, or for any purpose not directly related to the reasonable costs of conducting the research (as specified in the research agreement between the sponsor and the University), as determined through reference to public prices or other reasonable measures of fair market value, either in the year prior to the grant application or initiation of unsponsored research and submission of the accompanying Disclosure Form, or in the twelve months following the grant application or initiation of unsponsored research;
Greater than 1% of the ownership of stock, assets or profits of a company which has, or seeks to have an agreement with the University, where the agreement is for the development of scientific or technological discoveries or innovations in which the University has or will have a property right.
Equity interests, including stock options, of any amount in a non-publicly traded financially interested company (or entitlement to the same);
Equity interests (or entitlement to the same) that in aggregate exceed $5,000 in a publicly-traded financially interested company;
Q: An Investigator owns stock in a company, Reagents Are Us, valued at $10,000. The Investigator's lab purchases reagents from the company for use in her lab. Must the Investigator disclose the stock holdings?
A: Yes. If the investigator can influence the decision as to which company sells reagents to her lab, she must disclose the financial interest because it relates to her institutional responsibilities. This kind of financial interest is unlikely to be determined to affect or potentially affect research. It is, however, likely to be an issue under the State ethics rules.
Q: What is the definition of institutional responsibilities?
A: Generally speaking this includes teaching, research, administration, and professional practice; as well as other activities that involve the same expertise for which Rutgers employs the Investigator. For example: a geneticist who writes a textbook on genetics would disclose it; a geneticist who wrote a science fiction book that requires an understanding of genetics would disclose that also; but if a geneticist wrote a book on baseball, that would not be disclosed.
Q: Is an Investigator required to report equity, stocks or stock options that are not related to their institutional responsibilities? (Teaching, research, administration, and professional practice.)
Q: If a microbiologist holds stock in a publicly-traded company that produces patio furniture, would that be disclosed?
A: No, that type of manufacturing is unrelated to the Investigator's institutional responsibilities.
Q: If a microbiologist hold stock in a publicly-traded company that produces patio furniture, and he consults for the company regarding anti-microbial treatments for seat cushions, would that be disclosed?
A: Yes, if both the stock value combined with the consulting fees exceeded $5,000 in the last 12 months.
For Publicly Traded Companies
Q: If the financial interests of the Investigator are related to her institutional responsibilities at Rutgers, and if her remuneration and equity combined exceeded $5,000 (in the preceding 12 months), would the interests be disclosed?
For Non-publicly Traded Companies
Q: If a company remunerates an Investigator for activities related to the Investigator's institutional responsibilities, and the remuneration exceeded $5,000 in the preceding 12 months, would the interest be disclosed?
Q: If the Investigator instead only owned equity, and there was no remuneration, would that be disclosed?
A: Yes, there is no threshold for disclosing equity, since no specific value can be attributed to equity in a privately-held firm. The existence of an interest would be disclosed but not quantified
Q: Why is the dollar value of stocks or other equity not disclosed for non-publicly traded entities?
A: Because the value of the stocks are not readily available.
Q. What is "Sponsored Travel"?
A. Reimbursed or sponsored travel is related to the investigator's institutional responsibilities (and includes the purpose of the trip, the name of sponsor/organizer, the destination, the duration of the trip).
PHS grant-funded travel does NOT need to be disclosed.
"Sponsored" in this case means paid directly to vendors ie the investigator may not even know the costs involved.
Q. Why disclose Sponsored Travel?
A. The federal regulations require all PHS funded investigators to "disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities..." 42 CFR §50.603.
Q. Who must disclose Sponsored Travel?
A. Any principal investigator or any member of the key personnel on any project funded by the U.S. Public Health Service, (for example NIH). Key personnel means the PD/PI and any other person identified as key personnel by the Institution in the grant application, progress report, or any other report submitted to the PHS by the Institution under this regulation.
Q. What Sponsored Travel should be disclosed?
A. Includes but not limited to:
- Reimbursed or sponsored travel related to Institutional responsibilities (including the purpose of trip, sponsor/organizer, destination, duration). Exceptions for travel are listed in the next section.
- Travel that is reimbursed or paid directly for consulting.
- Travel that is reimbursed or paid directly by a for-profit or non-profit organization for a conference, or to participate in a meeting.
- Travel that is reimbursed or paid directly when the investigator has a financial interest in that entity, ie a start-up
Q. What Sponsored Travel is not disclosed?
A. The types of Sponsored Travel that do not need to be disclosed include:
- Travel that is reimbursed or paid directly by a federal, state, or local government agency
- Travel that is reimbursed or paid directly by an institution of higher education as defined at 20 U.S.C. 1001(a) (or in plain English, a university)
- Travel that is reimbursed or paid directly by an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education
- Travel reimbursed or paid directly by non-profit organizations in which Rutgers is a member institution and for which the investigator serves as a member of its governing board, a panel or a task force where such service has been approved by the Rutgers.