Those responsible for the design, conduct, or reporting of sponsored activity are required to submit a disclosure of Significant Financial Interests (SFIs) for themselves, their spouse, and their dependent children:

• Annually
• Within 30 days of acquiring a new SFI
• Within 30 days of a change to a previously reported activity or financial interest.

Disclosures are submitted using the Research Administration Portal.

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.

Activities That Require Disclosure

The Financial Conflict of Interest in Research Policy specifies which outside activities and interests require disclosure.

An investigator's disclosure should include Significant Financial Interests for them, their spouse, and their dependent children. In the same disclosure, investigators should also disclose current and future outside activities as required by the Conflict of Interest, Conflict of Commitment, Outside Activities (COI/COC) Policy.

Significant Financial Interests include:

1. Remuneration received from a publicly traded entity that, when aggregated, exceeds $5,000 in the previous 12 months. Remuneration includes salary, equity interests, and any payment for services such as consulting fees, honoraria, and paid authorship. Equity interests include stock, stock options, or other ownership interests.
2. Remuneration received from a non-publicly traded entity that, when aggregated, exceed $5,000 in the previous 12 months OR any equity interest.
3. Any income received from intellectual property rights and interests UNLESS the UO is managing the intellectual property and the income comes from the UO.
4. Reimbursed travel or sponsored travel paid on behalf of the investigator that, when aggregated, exceeds $5,000 from any one entity. The travel must be related to the investigator's institutional responsibilities. Travel reimbursed or sponsored by a local, state, or federal agency or by a U.S. institution of higher education is exempt.

Activities That Do Not Require Disclosure

Activities and interests that are exempt from disclosure under the FCOI Policy include:

1. Salary, royalties, or other remuneration paid by the UO, including royalties for intellectual property rights assigned to the UO.
2. Income from investment vehicles, such as mutual funds and retirement accounts, IF the investigator does not directly control the investment decisions.
3. Payment from a local, state, or federal agency or a U.S. institution of higher education for seminars, lecturers, teaching engagements, or service on advisory committees or review panels.
4. Travel reimbursed or sponsored by a local, state, or federal agency or by a U.S. institution of higher education.

Investigators who are unsure if their outside activity is exempt are welcome to browse our FAQ page or contact us directly.

Congruence Among Disclosures

In current/pending support documents and biographical sketches submitted to a sponsor, even if there is no monetary value, researchers must disclose:

• Organizational affiliations and employments
• External positions and appointments
• Foreign government-sponsored talent recruitment programs
• Access to lab space
• Honorary titles, degrees, and lab space at other institutions 

Outside activities that are not subject to the UO’s Financial Conflict of Interest in Research Policy but should still be reported in a conflict of interest disclosure submitted to the UO so that the disclosure matches a biosketch and current/pending support documents include:

• Honorific titles
• Unpaid appointments, including unpaid board service
• Outside activities resulting in less than $5,000/year 

How Do I Disclose?

Investigators submit disclosures of their outside activities and financial interests using the Research Administration Portal (RAP).

A Note About Required Training

Investigators must also complete financial conflict of interest (FCOI) training as required by UO's FCOI Policy and federal regulations.

Federal regulations mandate training for investigators every four years, and the UO requires training every three years.

An investigator with expired training cannot complete a new disclosure without first completing the required training to ensure compliance with federal regulations.

The UO uses the Collaborative Institutional Training Initiative (CITI) to administer the required training. Download our step-by-step guide for adding the COI Researcher module. You're also welcome to email us and we can add it for you.

Completing the training satisfies the requirement for three years, and investigators must pass the COI Researcher module with an 80% score or higher.

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