Tag Archives: SFI

Use this section to enter a description of your interests and interactions with this entity.  Describe what you do with this entity.  you must complete this field, which has a limit of 1,000 characters.

s f i summary section

This section will display if “Reimbursed or sponsored travel” was selected in the Entity Nature of Interest section.

Travel Expenses: Expenses incurred for the purpose of engaging in travel activity, including but not limited to, costs for transportation, parking, food, drink, lodging, and related amenities.

Within this section, you can add new travel and copy or delete current travel entries.

Note: Travel entries that are more than one year old or more than a year in the future are not considered part of the SFI being disclosed. Therefore, older travel entries will not display as part of the SFI entity. You will also not be able to add new travel that is more than a year in the future.

Add New Travel

To provide details about travel, click the Add New Travel button, as show in the following image.

add new travel
A window will open for you to enter your travel information.

add travel fields
Within this window, click Add to save what you’ve entered, or the Cancel link or icon (X) to close the window.

Field Description
Value of Travel This value must be zero or greater. You may include the dollar sign ($), commas and a period in this field. This is a required field.
Destination Enter the name of the destination. There is a limit of 50 characters. This field is required.
Start Date of Activity Use the pop-up calendar to select a date, or type one in using the month/day/year format (e.g., 10/31/2022). The start date must be within the preceding 12 months, or the next 12 months. This field is required.
End Date of Activity Use the pop-up calendar to select a date, or type one in using the month/day/year format (e.g., 10/31/2022). The date can be the same as the Start Date or a later date. This field is required.
Sponsored or Reimbursed Select the appropriate choice from the menu. You must select at least one choice.

  • Sponsored
  • Reimbursed
Sponsored Travel: Any travel for which the Travel Expenses are paid directly by an outside entity (with some exceptions).

Reimbursed Travel: Any travel activity for which the Travel Expenses are paid directly by the Investigator, who is then reimbursed by an entity for such Travel Expenses (with some exceptions).

Exceptions: Sponsored or Reimbursed Travel shall not include Travel Expenses that are reimbursed by 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.

For more information, see Travel Disclosures in GIM 10.

Foreign or Domestic Select the appropriate choice from the menu. You must select at least one choice.

  • Foreign
  • Domestic
Purpose of Trip Enter a description of the purpose of the trip. There is a limit of 500 characters. This field is required.
Please indicate if (check all that apply) Select all choices that apply.

  • Your spouse/domestic partner, or other family members, accompanied you on this trip.
  • Additional personal recreational activities extended the duration of this trip

Copy or Delete Travel Entries

If you have an existing entry for a trip, you can copy or delete the entry as shown in the following image.

travel entry copy or delete
You can click the Copy link to use some of an existing entry’s data for a similar entry. The same dialog used to add new travel will appear with these fields copied:

  • Value of Travel
  • Destination
  • Sponsored or Reimbursed
  • Foreign or Domestic
  • Purpose of trip
  • Indicator check boxes

If you need to remove a travel entry, you can click the Delete link. You must confirm the deletion.

Investigators must disclose royalties that they receive from non-UW sources (royalties from UW are considered remuneration). This section will display if you selected “Intellectual property” in the Entity section. Use it to provide details.

Intellectual Property: The rights comprising a patent, trademark, copyright, trade secret, know-how or other similar intangible property right, including but not limited to, inventorship or authorship.

Mutual funds and retirement accounts that the Investigator does not directly control are not considered SFI.

The following image shows this section.

Fields

IP Type

Select the appropriate choice(s) from the menu. You must select at least one choice.

  • Patents
  • Royalties
  • Other

Note: If you selected Other, an additional explanation field will display. You must enter an explanation. The system will discard any text you entered in the explanation field if you deselect Other.

Income Earned from IP

This value must be zero or greater. You may include the dollar sign ($), commas and a period in this field. This field is optional.

Investigators must disclose equity and equity options that they receive. This section will display if you selected “Equity Interest” in the Entity section. Use it to provide details on the equity you hold in the named entity.

Equity: Any interest in the profits of, or other ownership interest in any commercial or non-profit enterprise, including common stock and other equity securities, and any right to acquire any of the foregoing such as an option, warrant or other security convertible into an equity security.

The following image shows the Equity section with Dollar Value Unknown checked to display the Explain field.

Fields

Value of Equity

You must enter this value unless you checked the Dollar Value Unknown check box. The value must be zero or greater. You may include the dollar sign ($), commas and a period in this field.

Dollar Value Unknown

Check this if the value of the equity is unknown. If checked, an explanation field will display. You must include an explanation.

Explain (If dollar value unknown)

This field will display only if you selected the Dollar Value Unknown check box. This field is required when it displays. The system will discard any text entered in this field if you deselect the check box. There is a maximum of 500 characters.

Percentage Ownership

This field will display if you selected the Entity type “For Profit: Privately Held”. This field is required when it displays. Type in the percentage ownership.

Date Equity Acquired

Use the pop-up calendar to select a date, or type one in using the month/day/year format (for example, 10/31/2013). This field is required.

Investigators must disclose compensation from external sources. This section will display if you select “Compensation” in the Entity section. Use it to provide details on the amount and type of compensation you have received or are receiving from the named entity.

Compensation includes salary and/or payment for services.

Fields

Annual Value of Compensation

This value must be zero or greater. You may include the dollar sign ($), commas and a period in this field. This is a required field.

Compensation Type

Select the appropriate choice(s) from the menu. You must select at least one.

  • Consulting Fees
  • Salary, wages, and honorarium
  • Retainer
  • Gift
  • Other

Note: If you select Other, the explanation field will display. You must enter an explanation. If you deselect Other, the system will discard any text you entered in the explanation field.  There is a maximum of 500 characters.

Category of Activity 

Select the appropriate choice(s) from the menu. You must select at least one.

  • Board Member
  • Consultant
  • Editor
  • Expert Witness
  • Performing Arts
  • Professional/Continuing Education
  • Professional/Private Practice
  • Reviewer
  • Scientific/Technical/Expert Advisor
  • Speaker
  • Other

Note: If you select Other, the explanation field will display. You must enter an explanation. If you deselect Other, the system will discard any text you entered in the explanation field. There is a maximum of 500 characters.

Start Date of Activity

Use the pop-up calendar to select a date, or type one in using the month/day/year format (for example, 10/31/2015). This field is required.

End Date of Activity (if available)

Use the pop-up calendar to select a date, or type one in using the month/day/year format (for example, 10/31/2018). This field is optional.

The SFI entity section captures details about the entity in which you hold significant financial interest. The Nature of Interest check boxes control what other sections display on the page.

Entity” means any domestic or foreign, public or private, for profit or not-for-profit legal entity or organization other than the University, any agency of the State of Washington, or the federal government (per GIM 10).

Fields

Name of Entity

This field holds a maximum of 250 characters and is required.

Entity Type

Select the appropriate type from the menu. This is a required field.

  • For Profit: Publicly Traded
  • For Profit: Privately Held
  • Not-For-Profit
  • Federal, State, or Local Government
  • Foreign Government/Institution of Higher Ed

Who holds this interest?

Select the appropriate choice from the menu. This is a required field. If you and a family member both hold SFI in the same entity, you will need to enter the information as two separate SFI entries.

  • Self
  • Immediate Family Member
    • This is defined as a person’s spouse, domestic partner, parent, grandparent, grandchild, sibling, child, or anyone who qualifies as the person’s dependent under the U.S. Internal Revenue Code.

Nature of Interest

Select all choices that apply. You must select at least one. For each choice you select, an additional section will display on the page for you to enter further details.

Note: PHS-funded investigators must disclose all Significant Financial Interests (SFI) related to their Institutional Duties, as defined by GIM 10.  FIDS will automatically link all existing SFI to any disclosure you created for a PHS-funded eGC1. A PHS eGC1 is one where either the sponsor or the originating sponsor is PHS. A list of PHS Sponsors is available. If you are creating a disclosure for a non-PHS eGC1, you will be able to indicate which of your SFI relate to the eGC1.

What is FIDS?

GIM 10 disclosures are made using a web-based electronic system called the Financial Interest Disclosure System (FIDS) which is linked to the SAGE system. This system replaces the paper-based procedure.

Are Investigators responsible for reporting the SFI of subcontractors?

In general, no.  Subrecipient institutions that meet the compliance requirements of the new PHS regulations will have their own reporting process; however, the subrecipient will need to provide the UW with the appropriate assurances as part of the subaward agreement. In the rare case where the UW might decide to manage a subrecipient’s SFI disclosures, the UW would be responsible for reporting the subrecipient’s disclosures to the sponsor.

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 equity in an outside entity whose business is related to your University research (e.g., 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 new PHS 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; e.g., where a spouse’s travel is paid for by an outside entity who also has a direct connection to your University research (e.g., your spouse works for the sponsor of your University research project), and her/his 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.

When must an Investigator disclose SFI that is unrelated to their current research project?

Example: an Investigator receives PHS funding to perform quantitative imaging and also does outside consulting for Amgen and AstraZeneca. The Investigator receives more than $5000 from each Entity for the consulting work, but the work involves drug development, not quantitative imaging.   Does the $5000 from each Entity need to be disclosed if the work is not related to research?

Under GIM 10, Investigators participating in PHS-Funded Research must report SFIs as related to their Institutional Responsibilities.  This is a broader disclosure than was previously required.  GIM 10 defines “Institutional Responsibilities” as  “any professional activity carried out by an Investigator or Innovator for which the Investigator or Innovator is compensated by the University, including:  (i) sponsored activities (such as Research, training, and similar activities sponsored by external sources including federal, state and local governments and private businesses, corporations, foundations and organizations), (ii) non-sponsored activities (such as teaching, departmental or University supported Research, clinical work, and department and University administrative duties), and (iii) University-related public service.”

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