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.

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