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All faculty members and other individuals who are responsible for the design, conduct or reporting of research or other educational activities which are funded, or proposed for funding, by external institutions are required to disclose whether they, their spouse/domestic partner, or any of their dependent children have any Significant Financial Interests related to their institutional responsibilities.

These disclosures are reviewed in accordance with Clark University’s policies regarding Financial Conflicts of Interest and if necessary a management plan will be developed to limit the potential for or perception of bias in the design, conduct or reporting of their research or other programs and activities.

Submit your FCOI Disclosure here

Financial Conflict of Interest Disclosure

Significant Financial Interest (SFI) — anything of monetary value including, but not limited to salary or other payments for services (e.g. consulting fees, honoraria, paid authorship), equity interests (e.g., stock, stock options or other ownership interests), investment income (e.g., dividends or interest), and intellectual property rights (e.g., patnts, copyrights) which reasonably appear to be related to the Investigator’s institutional responsibilities. This also includes reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator) reasonably related to their institutional responsibilities except with travel reimbursed or sponsored by a federal, state or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute affiliated with an institution of higher education.

This definition of SFI does NOT include:

  • SFIs less than $50001.
  • Income from seminars, lectures or teaching engagements sponsored by government entities, institutions of higher education, or research institutes affiliated with higher education institutions.
  • Income from investment vehicles (e.g., mutual funds, retirement accounts) assuming Investigator does not directly control the investment decisions made in those vehicles.

Investigator — principal investigator (PI), co-principal investigator (co-PI), and any other person (e.g., staff, researcher, student, postdoctoral fellow, visiting researcher, etc.) who is responsible for the design, conduct or reporting of sponsored research or other sponsored activities.

Senior/Key Personnel — project director/principal investigator (PD/PI) and any other person identified as Senior/Key Personnel by the institution in the grant application, progress report, or any other report submitted to the funding agency.

1 If the value of the financial interest cannot be determined then it should be assumed to be a SFI.

Failure to disclose a FCOI or to comply with management plans or other corrective actions can result in disciplinary actions or sanctions by the University and/or the funding agency. Disciplinary actions and sanctions may include suspension or dismissal, non-renewal of appointment, denial of eligibility to engage in funded research through the University, restitution, criminal prosecution, or other penalties. Sanctions may also require giving notice to the funding agency/sponsoring agency, professional associations, journals, and/or the public.

Records of all Investigator disclosures of financial interests and the University’s review of or response to such disclosures whether or not determined to be a FCOI will be maintained for at least three years from the expiration and final close—out of award.

Information submitted by Investigators will be treated as confidential and will not be disclosed except as required by law or the funding agency, or as may be deemed necessary by the University and any related sponsoring agency.