Under 42 CFR Part 50 Subpart F and the UO's FCOI Policy, investigators responsible for the design, conduct, or reporting of sponsored research must:
- Disclose annually all Significant Financial Interests for themselves, their spouse, and their dependent children related to their institutional responsibilities.
- Update their disclosures within 30 days of acquiring or changing a Significant Financial Interest
Disclosures are submitted using the Research Administration Portal (Duck ID required).
The Research Administration Portal is configured so that investigators' disclosures go into "action required" status within 60 days of their annual disclosure date. Investigators' disclosures must be in a "no action" required status prior to submitting a proposal and prior to Sponsored Project Services processing an award action on a new or existing award.
What Investigators Need to Disclose: Significant Financial Interests
A Significant Financial Interest includes any of the following held by the investigator, their spouse, or their dependent children that is related to their institutional responsibilities:
- Publicly traded entity: Remuneration that, when aggregated, exceeds $5,000 in the previous 12 months
- Non-publicly traded entity: Remuneration that, when aggregated, exceeds $5,000 in the previous 12 months or any equity interest
- Intellectual property income: Any income received from intellectual property rights and interests unless the UO manages the intellectual property and pays the income
- Sponsored or reimbursed travel: Reimbursed or sponsored travel paid on behalf of the investigator that, when aggregated, exceeds $5,000 from any one entity unless the travel is funded by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with an institution of higher education
- The travel must be related to the investigator's institutional responsibilities.
Remuneration includes salary, equity, stock, stock options or other ownership interest, and any payment for services such as consulting fees, honoraria, and paid authorship.
Investigators who are unsure whether to disclose an outside activity or financial interest may browse our FAQ page or email us. We respond to email inquiries within 2 business days.
What Investigators Don't Need to Disclose
The following do not constitute a Significant Financial Interest:
- Salary, royalties, or other remuneration paid by the UO, including royalties for intellectual property rights assigned to the UO
- Income from investment vehicles (e.g., mutual funds, retirement accounts) if the investigator does not directly control the investment decisions made in the vehicles
- Payments for seminars, lectures, teaching engagements, or service on advisory committees or review panels paid by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with an institution of higher education.
- Travel reimbursed or sponsored by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with an institution of higher education
A Significant Financial Interest Does Not Necessarily Mean a Conflict Exists
Once a sponsor has awarded a project to the UO, staff in the Conflict of Interest (COI) Office review an investigator’s Significant Financial Interests to determine whether a conflict exists with the specific sponsored research. The Conflict of Interest in Research Committee affirms this determination. If a conflict could or does exist, COI staff work with the investigator and the committee to develop or update a management plan.
Congruence Among Disclosures
The COI team reviews documents investigators submit to a sponsor (e.g., biographical sketch, current/pending support document) for consistency with their UO conflict of interest disclosure submitted in the Research Administration Portal.
If the COI Office find discrepancies, staff follow up with the investigator to determine if disclosure is required to either a sponsor or to the UO.
Investigators must disclose the following in sponsor documents, even if unpaid:
- Organizational affiliations and employments
- External positions and appointments
- Foreign government-sponsored talent recruitment programs
- Access to lab space at other institutions
- Honorary titles and degrees
Not sure what to disclose? Review the specific sponsor disclosure tables below, check our FAQs, or email us. We respond to email inquiries within 2 business days.
How to Disclose
Investigators submit disclosures of their outside activities and financial interests using the Research Administration Portal (RAP).
The Research Administration Portal is configured so that investigators' disclosures go into "action required" status within 60 days of their annual disclosure date. Investigators' disclosures must be in a "no action" required status prior to submitting a proposal and prior to Sponsored Project Services processing an award action on a new or existing award.
A Note About Malign Foreign Talent Recruitment Programs
Federal law (42 USC 19232) and sponsor regulations prohibit UO researchers who receive federal funds from participating in malign foreign talent recruitment programs (MFTRPs)—typically tied to a foreign entity located in a “country of concern” that offers compensation for inappropriate obligations.
A Note About SBIR/STTR Awards
The Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Programs fund small businesses conducting research and development. Close collaboration between university researchers and businesses can raise conflicts of interest. Early disclosure and management of these relationships help ensure transparency, reduce bias, and support seamless progress from Phase I to Phase II.
UO Guidance on Conflicts and SBIR/STTR Awards
Additional Disclosure Requirements
All UO employees are public officials under Oregon law.
The UO’s Conflict of Interest, Conflict of Commitment, and Outside Activities Policy (COI/COC Policy), derived from Oregon state ethics law, requires disclosure of specific outside activities and financial interests. This disclosure requirement is in addition to disclosing Significant Financial Interests under the FCOI Policy.