Last modified: Feb 21, 2013

Designated Official means either the unit chair, college Dean, or equivalent administrator (hereinafter referred to as "the Dean") or, in complex cases any member of the FCOI Management Team designated by the Institutional Official to review disclosures to determine if there is a relationship between an Investigator’s Significant Financial Interest and his or her research. The Designated Official is the individual within Northeastern University that is ultimately responsible for the review of disclosures of Significant Financial Interests and the management of Financial Conflicts of Interest.

Equity Interests means stock, stock options, warrants, and other existing or contingent ownership interests in a commercial entity.

Family means an Investigator’s spouse, domestic partner, and dependent children.

FCOI Management Team means Northeastern University’s committee with respect to conflict of interest matters.

Financial Conflict of Interest means a Significant Financial Interest that Northeastern University reasonably determines could directly and significantly affect the design, conduct, or reporting of research.

Institutional Official means the Senior Vice Provost for Research.

Institutional Responsibilities means the Investigator’s responsibilities associated with his or her Northeastern University appointment or position, such as teaching, scholarship, research, creative activity, service, etc., as defined in the Faculty Handbook.

Investigator means the principal investigator and any co-principal investigators for a research project.   This includes, but is not limited to, the project director, principle investigator, or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.

Outside Professional Activities means compensated and uncompensated activities undertaken outside of an Investigator’s Institutional Responsibilities.

Related Company means a commercial entity in which the Investigator, alone or in combination with his or her Family, holds a Significant Financial Interest.

Remuneration includes salary and payments for services, such as consulting fees, honoraria or paid authorship.

Senior/Key Personnel are identified in the grant application, progress report, or any other report submitted to the PHS, and include, but are not limited to, the program director/principle investigator (PD/PI) and other individuals who contribute to the scientific development or execution of a project in a substantive, measureable way, whether or not they request salaries or compensation.

Significant Financial Interest (SFI) means a financial interest or income received or held by an Investigator, alone or in combination with his or her Family (and not expressly excluded below) that reasonably appears to be related to the Investigator's institutional responsibilities.  Examples of SFI that must be disclosed are:

  1.  Interest or income in or from a publicly traded entity where
    • the aggregate value of Remuneration and any equity interest exceeds $5000 (any remuneration received during the 12 month period preceding the disclosure, or expected to be received in the 12 months after the disclosure; the value of any equity interests in the entity as of the date of disclosure)
    • the entity is sponsoring any of the Investigator’s research;
  2. Interest or income in or from a non-publicly traded entity where
    • the aggregate value of Remuneration exceeds $5000 (any remuneration received during the 12 month period preceding the disclosure, or expected to be received in the 12 months after the disclosure;) or when any equity Interests are held
  3. Interest in the form of income related to intellectual property rights and interests paid by an entity other than Northeastern University
  4. Travel related to Institutional responsibilities not reimbursed or sponsored by Northeastern University, including but not limited to travel sponsored by international universities, corporate sponsors, foundations e.g. American Cancer Society, American Heart Association, etc.
  5. Phase II SBIR/STTR applications

Significant Financial Interest does NOT include:

  1. Remuneration or Royalties paid by Northeastern University to the Investigator;
  2. Remuneration from authorship of academic or scholarly works;
  3. Remuneration and sponsored/reimbursed travel related to seminars, lectures, or teaching engagements sponsored by, or from advisory committees or review panels for, U.S. Federal, state, or local governmental agencies; U.S. institutes of higher education;  U.S. research institutes affiliated with institutes of higher education, academic teaching hospitals, and medical centers;
  4. Equity Interests in or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions for these vehicles.
  5. Phase I SBIR/STTR applications


In part, definitions are based on those approved by the Faculty at the Massachusetts Institute of Technology in July, 2012.