The Conflicts of Interest Disclosure Form for all Sponsored Research and its associated cover memorandum clarify the significant financial interests and foreign affiliations that must be disclosed in accordance with sponsor requirements and GW’s Policy on Outside Interests, Relationships, and Professional Activities.
Completed forms should be submitted to [email protected].
Below are commonly asked questions and answers regarding the completion of the Financial Disclosure Form. For further guidance or questions, please email [email protected].
- Who must complete a PHS Financial Disclosure Form?
All investigators on a project are required to complete the PHS Financial Disclosure Form before applying for federal funding or commencing work on a federally funded project and then annually thereafter. There must be updated disclosures on file for all persons responsible for the design, conduct or reporting of research on the proposal.
An investigator is defined as:
- the project director or principal investigator;
- any other person, regardless of title or position, who is responsible for the design, conduct or reporting of research on the PHS funded award, or proposed for such funding;
- which may include, for example, collaborators or consultants.
Postdocs and graduate students may also be covered by the regulations if they meet the definition of investigator as outlined above.
- When must a PHS Financial Disclosure Form be Completed?
Federal regulation and GW policy requires that the disclosure form is filed:
- prior to the submission of any proposal to a PHS funded agency;
- annually, if the investigator is participating in PHS funded research, even if the investigator does not have any new significant financial interests to report; and/or
- within thirty days of acquiring any new reportable interest, discovering an interest that was not disclosed in a timely fashion, or other updates that would alter your disclosure form.
In the event that the proposal is funded, disclosures for all Investigators on the project will be reviewed by investigator’s Dean (or designee) and completion of CITI’s FCOI training modules for each investigator will be verified prior to permitting any spending on the award.
Refer to GW’s Policy on Conflicts of Interest and Commitment for Faculty and Investigators for more information.
- Joining the University of a project that is already in process
All new investigators to the university are required to submit a financial disclosure form and complete CITI’s FCOI modules prior to engaging in PHS funded research.
Please notify [email protected] immediately if there will be a new investigator working on your project, and ensure that forms and training are completed in a timely manner as to not delay the start of any Investigator participating on the PHS funded project.
- Requirements for subrecipients and consultants
If a subrecipient or consultant does not have a PHS FCOI compliant policy, they must comply with GW’s policy. The subrecipient or consultant will go through the same process that GW investigators must follow (i.e. submitting Financial Disclosure Forms to [email protected], providing proof of CITI FCOI training completion, review by the Dean or Dean’s designee, etc.).
Collaborating institutions that have a PHS FCOI compliant policy can be identified via the Federal Demonstration Partnership's FCOI Institutional Clearinghouse. For more information on this process, please contact [email protected].
- Non-PHS Federal Funding
Furthermore, all investigators on a project are required to complete the following supplemental disclosure form in advance of applying for non-federal funding.
In cases of non-compliance related to PHS funded awards, GW is required to conduct a retrospective review of the Investigator’s activities and determine whether the research or scholarly activity, or any portion thereof, conducted during the time period of noncompliance, was biased in design, conduct, or reporting.
- Exclusions from Reporting Requirements
Compensation from the following entities does not need to be disclosed: Federal, state, or local government agencies, institutions of higher education as defined at 20 U.S.C. 1001(a), academic teaching hospitals, medical centers, or research institutes that are affiliated with an institution of higher education.
- Where are financial disclosure forms are stored and who has access to view the information?
In order to protect the privacy of Investigators, there is a controlled and limited number of people who have access to the financial disclosure forms. The forms are stored in a database that can only be accessed by OVPR’s research compliance officer, finance director of the investigator’s school, and dean or dean’s designee. If you are an investigator and would like access to your disclosure forms, please contact [email protected].
- Who can I contact for additional questions or support?
Questions may be directed to the Office of Research Integrity at [email protected] or you may contact your departmental or sponsored projects administrator for assistance.