When must Investigators disclose Significant Financial Interest (SFI)?
Full and prompt disclosure is critical to Northeastern University’s ability to identify, manage, and eliminate Financial Conflicts of Interest. There are three types of disclosures:
- Annual Disclosures. Investigators must disclose their Significant Financial Interests to Northeastern University on an annual basis via COEUS, and must disclose certain information with respect to conflicts of commitment and interest as prescribed in the Faculty Handbook.
- Proposal-related Disclosures. Prior to submitting a proposal for funding, the Principal Investigators identified in the proposal and, if requested by the Institutional Official or the Designated Official, other Investigators associated with the proposal must disclose whether the Investigator’s Significant Financial Interests may be related by the proposal. If there is a potential relationship, the Investigator must file a full disclosure with additional information regarding the relationship of the project to the Related Company prior to submission of the proposal to the sponsor.
- Ad hoc Disclosures.
- An Investigator must disclose via COEUS on an ad hoc basis any new Significant Financial Interest within 30 days following the date on which the Significant Financial Interest is acquired or arises. This 30 day requirement is specific to the PHS regulations.
- An Investigator must disclose via COEUS on an ad hoc basis his or her Significant Financial Interests prior to the Investigator commencing participation in an existing research project.
**Northeastern University’s COEUS application is being upgraded with SFI disclosure functionality. Once this system upgrade is completed, the Office of Research and Administration (ORAF) will be contacting PHS funded Investigators with additional information and training.
What is considered a Significant Financial Interest and must be disclosed?
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:
- 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; 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;
- 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 when any equity Interests are held
- Interest in the form of income related to intellectual property rights and interests paid by an entity other than Northeastern University
- 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.
- Phase II SBIR/STTR applications
Significant Financial Interest does NOT include:
- Remuneration or Royalties paid by Northeastern University to the Investigator;
- Remuneration from authorship of academic or scholarly works;
- 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;
- 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.
- Phase I SBIR/STTR applications