UCM General Financial Conflict of Interest Disclosure

This Financial Conflict of Interest Disclosure is necessary for UCM to maintain federal compliance with PHS regulations set forth in 45 CFR Part 94 (https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-94) and 42 CFR Part 50, Subpart F (https://www.ecfr.gov/current/title-42/chapter-I/subchapter-D/part-50/subpart-F). These regulations are in place to avoid possible bias as a result of any conflicting financial interest by Investigators/Project Directors. Additionally, this disclosure is designed to protect research subjects, ensuring they will not be jeopardized by conflicting financial interests of Investigators. (Please see below for definitions of Significant Financial Interest.) The information requested is required under the Financial Disclosure Policy of the Public Health Services (PHS), the National Science Foundation (NSF), the Food and Drug Administration (FDA) and other public and private funding sources.


BEFORE COMPLETING THIS DISCLOSURE, 42 CFR Part 50 requires UCM to "inform each Investigator of the Institution's policy on financial conflicts of interest, the Investigator's responsibilities regarding disclosure of significant financial interests, and of these regulations, and require each Investigator to complete training regarding the same prior to engaging in research." Therefore, Investigators/Project Directors are required to successfully pass the CITI Program's Financial Conflicts of Interest Course. (https://www.citiprogram.org). This course will need to be successfully completed once every four years.


This Financial Conflict of Interest Disclosure must be certified at time of application, at time of award, and annually thereafter, throughout the lifetime of sponsored program activity at UCM. Investigators must also submit and certify a new disclosure within 30 days of the development and/or termination of a financial conflict.


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[OSPRI Only: 5/7/24]

Principal Investigator / Project Director

Training Certification

BEFORE CERTIFYING this UCM Financial Conflict of Interest Disclosure, Principal Investigators/Project Directors are required to successfully complete the CITI Financial Conflict of Interest Training Course. This brief training course is available to all members of UCM at no charge. Once successfully completed, this training is valid for four years. This training course can be found at this link: https://www.citiprogram.org . Contact osp@ucmo.edu for assistance.

CITI Training Certification for UCM Financial Conflict of Interest Disclosure*

I certify that I have successfully completed the CITI Financial Conflict of Interest Training Course within four years of today's date.

Unable to Proceed

You cannot continue to certify your Financial Conflict of Interest Disclosure until you have completed the CITI Conflict of Interest Training Course and certify "True" above. You can access this training course at this link: https://www.citiprogram.org/ . Contact osp@ucmo.edu for assistance.

Assurances

BEFORE CERTIFYING this UCM Financial Conflict of Interest Disclosure, the Principal Investigator/Project Director must certify that they agree to the following assurances for all their UCM sponsored project activity:


1) At proposal, at award, or otherwise on an annual basis throughout their sponsored projects' lifetimes, as requested by the Office of Sponsored Programs & Research Integrity, the Principal Investigator/Project Director will certify that this Financial Conflict of Interest Disclosure is accurate. If this disclosure is no longer accurate, or if within 30 days of discovering or acquiring a new reportable financial conflict of interest with any sponsored project, the Principal Investigator/Project Director will certify a new Financial Conflict of Interest Disclosure.


2) The Principal Investigator/Project Director will cooperate in the development of a resolution plan to address any actual or potential financial conflicts of interest that may be identified in this disclosure statement or that may arise in the future, for any of their sponsored projects.


3) The Principal Investigator/Project Director will comply with any reasonable conditions or restrictions imposed by UCM to manage, reduce, or eliminate actual or potential conflicts of interest, up to and including forfeiture of an award if deemed necessary.


4) The Principal Investigator/Project Director agrees that actual or potential financial conflicts of interest may be reported to funding agencies if required by state or federal regulations or by the funding agency guidelines.

Assurances Certification*

I certify that I agree to comply with the above four assurances throughout the lifetime of my sponsored projects activity at UCM:

Unable to Proceed

You cannot continue to certify your Financial Conflict of Interest Disclosure unless you agree to the above four assurances.

Definitions

The term 'significant financial interest' means anything of monetary value greater than $5,000, including, but not limited to, salary, stock, stock options, dividends, or other payments for services (e.g. patents, copyrights, and royalties from such rights). The term does NOT include: a. salary, royalties, or other remuneration from the University; b. income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; c. income from service on advisory committees or review panels for public or nonprofit entities; or d. an equity interest that when aggregated for you, your spouse, and dependent children is both not more than $5,000 e. salary, royalties, or other payments that when aggregated for you, your spouse, and dependent children for the next twelve months, is expected to be not more than $5,000.

Financial Conflict of Interest Disclosure Certification

By certifying this UCM Financial Conflict of Interest Disclosure, the Principal Investigator/Project Director agrees to disclose any significant financial interests (as defined above) in any person or entity involved with their projects which are greater than $5,000 for their self, their spouse, and their dependent children. The Principal Investigator/Project Director agrees to disclose any substantial financial interests (defined above) related to membership in any entity related to this project (including but not limited to director, officer, partner, trustee, employee, equity position, controlling interest).

Financial Conflict of Interest Disclosure and Certification*

As Principal Investigator/Project Director, I certify that my below disclosure reflects any and all conflicting financial interests, as defined above, currently and anticipated within the next 12 months, for all my UCM sponsored project activity:

Because you certified that you DO HAVE a significant Financial Conflict of Interest, a member of Sponsored Programs and Research Integrity will be reaching out to you soon to develop a resolution plan. Please provide the following information regarding your financial conflict(s) of interest:

List the grant code and/or title of all projects in which you have a significant Financial Conflict of Interest:

Please list any people or entities with which you are associated that would be affected by your participation in your UCM sponsored project activity:

Please list any income, equity interests, and intellectual property rights you have with these people or entities:

Please upload any supporting documentation here, including your certificate of completion of the CITI Financial Conflict of Interest Course, if available.

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