FAQ

Travel

Does an Investigator with a sponsor requiring UW SFI review need to disclose Sponsored or Reimbursed travel that is paid through a UW research budget?

No.  Travel disclosure is not required if the travel funding is paid through a UW budget (for example: sponsored award, gift, discretionary funds).

Since GIM 10 requires that I disclose my imputed SFI, does this mean that I have to disclose my spouse’s travel, even though s/he is not employed at the UW?

Most likely, the answer is “no”: as defined in GIM 10, imputed interests usually involve a partner/family member/spouse’s working for or having equity in an outside entity whose business is related to your University research. Ffor example, ownership in a company that could profit based on the outcome of your University research project.

The travel disclosure requirement is applicable to University personnel, since the regulations define travel paid for by an outside entity directly to the recipient to be SFI; this requirement does not apply to non-University personnel.

Travel expenses incurred by spouse/partner/family member are not a Financial Interest UNLESS they contribute to a University researcher’s SFI.  Therefore only if a spouse’s (or partner’s or other immediate family member’s) travel expenses, when combined with other financial interests of the same outside entity, create an imputed SFI do such things need to be disclosed.

There may be rare cases; for example, where a spouse’s travel is paid for by an outside entity who also has a direct connection to your University research (such as when your spouse works for the sponsor of your University research project), and their total amount of compensation or equity in the outside entity crosses the threshold for SFI that could appear to have a biasing effect on your University research. Since travel could be construed to be considered a form of compensation, it may be a judgment call as to whether such a situation becomes an imputed SFI. If there is any question about such examples, please contact the Office of Research for guidance.

I was a speaker at a national meeting for pancreatic cancer and recently had travel reimbursed by the meeting’s sponsor, American Association of Cancer Researchers (AACR) which is a non-profit. What do I need to disclose under GIM 10?

The disclosure requirements will depend on the type of research in which you are engaged.

Funded Research that requires UW Review:  If you are an Investigator for Funded Research and the sponsor requires UW review, you will need to disclose the following:

  • Travel:  Professional societies and non-profit organizations are not excepted from the travel disclosure requirement.  The occurrence of this travel, including an estimate of the value of the travel, must be disclosed within thirty (30) days of the occurrence of the travel.
  • SFI: If the travel expenses and any compensation received for this activity total $5000 or more, you must disclose this SFI.  (This is in addition to the above travel disclosure.)

All Other Funded Research: If you are an Investigator who participated ONLY in Funded Research where UW review is not required, you will need to disclose the following:

  • SFI: If the travel expenses and any compensation received for this activity total $5000 or more AND relate to a proposed or ongoing research project, you must disclose this SFI.
A listed exception to the Travel Disclosure requirement is travel that is sponsored or reimbursed by “a research institute that is affiliated with an Institution of Higher Education.” Is there a list of what research institutions will qualify?

At present, the UW has multiple affiliated research institutes, including FHCC, Seattle Children’s SCRI, SIBCR and the Howard Hughes Medical Institute.  A list of eligible institutes affiliated with the UW will be published on the FCOI website as these relationships are clarified.

What travel must be disclosed? How will Investigators make the required travel disclosures?

PHS-funded Investigators must disclose all Reimbursed or Sponsored Travel that is related to their Institutional Responsibilities.

GIM 10 definitions:

  • Sponsored Travel is travel activity, the Travel Expenses for which are paid directly by an Entity on behalf of an Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available to the Investigator.
  • Reimbursed Travel is travel activity for which the Travel Expenses are paid directly by the Investigator, who is then reimbursed by an Entity for such Travel Expenses.

Exceptions to the Travel Disclosures are Reimbursed or Sponsored Travel paid by the University, a federal, state or local government agency, an Institution of Higher Education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of Higher Education.

Travel Disclosures must be made within 30 days of the occurrence of travel and may be made up to twelve (12) months in advance.  The Travel Disclosures will be made through the Financial Interest Disclosure System (FIDS); in the same manner SFI will be disclosed.