August 21, 2012

SFI disclosure policy information and new SFI disclosure tool

Dear Colleagues:

The main purpose of this email is to inform you of the Significant Financial Interest (SFI)
disclosure policy and to announce the availability of the Financial Interest Disclosure System (FIDS).
FIDS replaces the existing paper-based system (as described in the current version of GIM-10)
to submit SFI disclosures. Investigators must now use FIDS to electronically submit their SFI and travel
disclosures. Please note that eGC1s that are created on 8/17/2012 or later will automatically pull information from FIDS and the paper based process will no longer apply.

* The definition of an “Investigator” includes the Principal Investigator (PI) and any
other University person (regardless of title or position) that the PI identifies as independently
responsible for the design, conduct, or reporting of the research; changes to the eGC1 form in
SAGE will permit the PI to identify which key personnel meet this definition on new proposals.

Who should disclose and when?

1. 1. SFI Disclosures by Investigators
      1. Public Health Service (PHS)-funded Investigators are required to disclose all SFIs that are related to their institutional responsibilities, no later than submission of an application for PHS-funded research or, if during an ongoing research project, within thirty (30) days of acquiring the SFI.
      2. Non-PHS-funded Investigators are required to disclose only those SFIs that
         are related to their research, and no later than submission of an application
         for the related research; or if during an ongoing research project, within thirty (30) days of acquiring the SFI.
      3. For ongoing research projects –
         1. All Investigators shall submit SFI Disclosures within thirty (30) days of acquiring any new or increased SFI, and;
         2. When a new Investigator joins an ongoing research project,
            the new Investigator shall submit SFI Disclosures within thirty (30) days of joining the project.
         3. Investigators who haven’t submitted any new disclosures within
            twelve months of an initial disclosure will be prompted to update their
            disclosure status (i.e., an Annual Update is required unless an investigator’s
            record is otherwise refreshed).
      4. All Investigators who receive funding on or after August 24, 2012,
         even if they previously disclosed SFI through the paper process, will be
         required to re-disclose SFI through FIDS to ensure that their SFI is accurately
         reported to the Office of Research and OSP.
      5. Investigators with existing awards (i.e., awarded before August 24, 2012) will
         not need to re- disclose SFI through FIDS for their currently funded awards.
         However, they will be required to use FIDS to capture SFI disclosures on future proposals.
   2. Travel Disclosures
      1. 1. PHS-Funded Investigators are required to disclose all travel that is
            either sponsored by or reimbursed directly to the investigator
            (i.e., paid by an outside entity), with some exceptions**.
            Note that travel disclosure does not apply to any travel paid via a
            University budget. The timing of Travel Disclosures shall be as follows:
            1. At the time of application for PHS-funded research, all sponsored travel and reimbursed travel paid directly to an
               individual by an outside entity occurring after August 24, 2012 must be disclosed, and;
            2. Thereafter, during the course of the Investigator’s participation in PHS-funded Research:
               1. No more than thirty (30) days after the occurrence of any sponsored travel or reimbursed travel.
               2. If a PHS Investigator is able to reasonably anticipate the occurrence of sponsored
                  travel or reimbursed travel, the Investigator may elect to submit Travel Disclosures up to
                  twelve (12) months in advance of the anticipated travel. Unless an advance Travel
                  Disclosure becomes materially inaccurate, no further disclosure of such travel shall be required.

      ** Exceptions include: travel reimbursements from an institution of higher
      education, a federal/state/local government, an academic teaching hospital,
      a medical center, or a research institute affiliated with an institution of
      higher education. Travel disclosures will be made using the electronic
      disclosure system. This disclosure requirement does NOT apply to funding
      provided to the investigator via the UW (e.g., as part of sponsored research
      projects; use of departmental discretionary or gift funds).

      1. Non PHS-funded Investigators shall submit Travel Disclosures through FIDS in accordance with the following:
         1. Non-PHS-funded Investigators shall disclose sponsored travel and reimbursed travel from an entity if:
            1. Either solely or when aggregated relative to the same outside entity, with the value of compensation,
               equity or intellectual property, the total value constitutes an SFI (for more details, see the Financial Conflict of Interest (FCOI) website), and;
            2. The SFI is related to their specific current or proposed research project.
         2. All Travel Disclosures that meet the threshold for SFI for Non-PHS-funded
            Investigators must include an estimate of the approximate value of the travel.
   3. Disclosures by Innovators

When an Innovator has an SFI related to a technology transfer transaction,
the innovator shall disclose the SFI prior to the conclusion of the technology
transfer transaction. All SFI Disclosures related to technology transfer
transactions shall be submitted by innovators. The University’s Center for Commercialization
(C4C) will be responsible for identifying innovators and ensuring that innovators who have an SFI
related to the proposed technology transfer transaction submit SFI Disclosures.

How do I access FIDS?

The FIDS website (https://www.washington.edu/research/tools/fids/) can be accessed
by anyone with a UW NetID. The following
information is available on the FIDS website:

• The Financial Interest Disclosure System (FIDS)
• Training on how to use FIDS
• The FIDS User Guide
• System and policy-related FAQs

How do subrecipients comply?

All subrecipients of PHS awards must have their own FCOI compliant
policy in place and make an assurance in the subaward (or subcontract)
to this regard. Reminders to the PI and eGC1 contacts regarding this requirement
will be sent by OSP at proposal stage, JIT and award stage for PHS-funded projects
in which subrecipients are proposed.

An example of a PHS-compliant FCOI policy for potential adoption by
subrecipients that do not yet have their own policy has been provided
by the Federal Demonstration Partnership (FDP):
http://sites.nationalacademies.org/PGA/fdp/PGA_061001

When will the revised policy be available?

GIM 10 and GIM 7 will be revised to ensure compliance with the new PHS
FCOI regulations and will be posted on the FCOI website by August 24, 2012.

We’ll keep you updated using email and the FCOI website: https://www.washington.edu/research/compliance/financial-conflicts-of-interest-fcoi/.

If you have any questions, please contact the Office of Research at: research@uw.edu.

Sincerely,

Jeff Cheek, Ph.D.

Associate Vice Provost for Research Compliance & Operations

Office of Research