Financial Conflicts of Interest Related to Research and Sponsored Programs

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  • The policy on Financial Conflicts of Interest Related to Research and Sponsored Programs applies to all University Research and Sponsored Programs – regardless of sponsor. There is one policy, one disclosure form, and one set of disclosure requirements. The policy applies to any research activity supported by university funds, regardless of source (“University Research”). University Research includes research activities that are not supported through Sponsored Program funds administered by the Office of Research and Sponsored Programs (ORSP) or the internal grant program administered by the Office of the Vice President of Research (VPR). For Sponsored Program activities that are supported by funds administered by the ORSP or the OVPR, there are no longer separate disclosure requirements for U.S. Public Heath Service (PHS)-Agency funded sponsored programs, other than PHS rules on acceptance of meals and travel expenses.

  • Project Personnel are required to disclose their Significant Financial Interests (SFIs), and those of their Family, that are Related to their research at the following times:
    • With each Sponsored Program proposal submission to ORSP.
    • Prior to acceptance of an award from research investment programs run by the OVPR.
    • Prior to engaging in University Research.
    • Within 30 days of material changes to circumstances that affect existing disclosures.

  • The dollar value threshold requiring disclosure of Related SFIs is $5,000.
    • For publicly traded External Entities: Project Personnel are required to disclose if the present value of their/their Family’s equity interest PLUS total compensation received directly/by their Family in the 12 months preceding the disclosure totals $5,000 or more.
    • For non-publicly traded External Entities: Project Personnel are required to disclose if they/their Family has received total compensation of $5,000 or more in the 12 months preceding the disclosure AND/OR they/their Family holds any equity interest, regardless of value.

All faculty and staff who engage in University Research are responsible for understanding their disclosure obligations pursuant to this policy and for notifying their Department Chair/direct supervisor prior to engaging in University Research if they have a related SFI to disclose.

Research Integrity and LTS are in the process of developing a new electronic system to enable faculty and staff to easily submit disclosures electronically. Originally scheduled for a Spring 2020 release, the development of the system was delayed due to COVID staffing limitations. The new system is now expected to be available by early 2021. In the meantime, ORSP and OVPR will continue to solicit disclosures with Sponsored Project proposals/awards, and Departments are required to contact Research Integrity when faculty members have SFIs Related to University Research to disclose.

For more information on the policy and how the requirements may affect you, please see the following:

or contact:

Naomi Coll, MPH, CPH, CIP
Director of Research Policy and Compliance
Lehigh University
Phone: 610-758-2985


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