This page displays when you click the Add new SFI link on the Disclose Significant Financial Interests page, or the entity name of an existing SFI to edit.
When adding new SFI, complete each of the sections on the page to provide all of the necessary details about your disclosure. These sections are described in the following articles.
For further information, review the Procedures section in GIM 10 – Financial Conflict of Interest Policy.
As you are completing your disclosure, you will see one of three versions of the Disclose Significant Financial Interests page. Which version you see depends on whether you have previously disclosed any SFI and whether your sponsor (or originating sponsor) is a Public Health Service (PHS) one. A list of PHS Sponsors is available.
The Disclose Significant Financial Interests page appears when you select Complete Disclosure or Create New Disclosure in the Action Items section and then select an eGC1 or CoMotion/IRB activity.
No Existing SFI
If you have not yet entered any SFI, you will need to indicate whether you have any SFI to disclose. The following image shows the question.
- If you do not have any SFI to disclose, just click Next to complete your disclosure.
- If you do have SFI to disclose, when you click on Next, the SFI Entry page will display for you to fill in your information.
Existing SFI – Non-Public Health Service (PHS) Sponsor
If you have existing SFI and your sponsor is not a PHS one, you must answer the question: Does your SFI pertain to this research activity?
- If you select No, then click Next, you will complete the disclosure. The disclosure will not include any of your existing SFI.
- If you select Yes, an additional question displays: Do you need to add new SFI or change existing SFI?
For this question, select No or Yes.
- Selecting No displays the Next button so you can continue.
- Selecting Yes displays a list of your current SFI, if any. You can then Add new SFI or click on the Entity Name of an existing SFI to edit it. When finished, click Next to continue.
Existing SFI – Public Health Service Sponsor
A disclosure for a Public Health Service (PHS) sponsor or originating sponsor automatically includes all of your existing SFI. So in this case, you just need to indicate if you want to add new or update existing SFI.
- If you select No and click Next, you will complete the disclosure.
- If you select Yes, then the list of your existing SFI will display, allowing you to edit any existing SFI or add new ones. The following images shows an example of existing SFI.
You can make changes to your SFI while you are completing a disclosure, either for a specific eGC1, for unsponsored activities, or just to disclose your SFI updates.
To delete an SFI entry, you need to be on the Disclose Significant Financial Interests page. You can access that page:
- By clicking on a Complete Disclosure button on the SFI Profile page, choosing I need to update my SFI, and clicking Next.
- By clicking the Create New Disclosure button on the SFI Profile page, choosing I need to add new SFI, change existing SFI, or for my annual update I need to reaffirm I have no SFI on the Disclosure Type page, and clicking Next.
On the list of your existing SFI on the Disclose Significant Financial Interests page, click the Name of Entity for the SFI you want to delete. The Significant Financial Interests page will display as shown in the image below.
- Click on the trash icon located in the top right corner, to the left of the save icon.
A dialog box will display, as shown below, with the note that deleting SFI will affect other disclosures.
- If you have included this SFI in a completed disclosure, you will need to provide an explanation for why you are deleting the SFI.
- The history of the change to the SFI will appear in any disclosure that included the SFI. See the History section for more details.
- Click the Delete button to complete the process.
- If you have not included this SFI in a completed disclosure, or if you do not have any PHS-sponsored eGC1 disclosure to which it has been automatically added, the dialog box will ask for a confirmation.
- Select OK to delete the SFI, as shown below.
Be sure to read the declaration.
To complete your disclosure, click the Submit Disclosure button. If you wish to cancel the disclosure, you can go back to the Profile Page using the breadcrumbs at the top of the page.
By submitting this form, I affirm that the information I have provided is true and complete to the best of my knowledge, and I agree:
- to provide any additional information, including further details of my financial interests, as requested by the Office of Research and, when applicable, the Office of the Vice Dean for Research, or their equivalent in my school/college
- to cooperate in the development of an appropriate Management Plan as required by the Office of Research
- to update this disclosure on an annual basis and to submit a disclosure of all new Financial Interests arising within 30 days of acquiring such interests
- to comply with all terms and conditions contained in any Management Plan
- to take reasonable measures to ensure that any of my Financial Interests that are less than a Significant Financial Interest do not adversely influence any Research or any person involved in any Research in which I participate as an Investigator or any Technology Transfer Transaction
This section displays all of your current SFI and includes the details about the Entity and any declared Compensation, Equity, Intellectual Property, or Travel.
You will see one of two versions depending on whether the sponsor and/or originating sponsor are PHS or not PHS for the primary eGC1, or if the disclosure does not have a primary eGC1.
PHS-Sponsored Primary eGC1
PHS-funded investigators must disclose all Significant Financial Interests (SFI) related to their Institutional Duties, as defined by GIM 10: Financial Conflict of Interest Policy. FIDS will automatically include all existing SFI in a disclosure for a PHS-funded eGC1. The following image shows an example list of existing SFI.
Special PHS Case
The sponsor type may shift from non-PHS to PHS rules for disclosures due to either a new sponsor being selected for the application or the current sponsor adopting PHS rules. If you completed your disclosure before the sponsor type (prime or originating) was changed to PHS, then your SFI list on that disclosure will not include all of your existing SFI.
If the disclosure is editable, you could update it to include any additional SFI. Any future disclosures made for the now PHS sponsor will automatically include all existing SFI.
Non-PHS Sponsored Primary eGC1 or No Primary eGC1
If the primary eGC1 does not have a PHS sponsor, you should indicate only related SFI. Specifically, SFI related to research means that the SFI either impacts, or could appear to impact, the design, conduct, or reporting of any current or proposed sponsored research projects.
Click the checkbox to include an SFI, or use the Select All or Deselect All links, as shown in the following image.
Use this section to complete a brief narrative, or description, outlining the connection between your research and your SFI. The following image shows this section.
You can see all of your existing Significant Financial Interests (SFI) listed in this section. The information displayed is
- Name of Entity
- Interest Holder
- Nature of Interest
- Entity Type
The following image shows an example list.
You can add, edit, or delete SFI when you are creating a disclosure. Select Complete Disclosure or Create New Disclosure in the Action Items section to start this process.
If you are an investigator for an eGC1 with a Public Health Service (PHS) sponsor, you must disclose all Significant Financial Interests (SFI) related to your Institutional Duties, as defined by GIM 10: Financial Conflict of Interest Policy. FIDS will automatically link all of your SFI to any PHS-funded eGC1 disclosures. An eGC1 is PHS-sponsored based on either the Sponsor or the Originating Sponsor. A list of PHS Sponsors is available.
If your eGC1’s sponsor is not PHS, you should only include those SFI related to the eGC1’s research. Specifically, SFI related to research means that the SFI either impacts, or could appear to impact, the design, conduct, or reporting of any current or proposed research projects.