How to Disclose?
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Internal Disclosures & Procedures:
Conflict of Interest (COI) *University Policy #107.03. This policy ensures disclosure and appropriate vetting of external activities to identify and remediate conflicts of interest. Submit your disclosure (annually and within 30 days of acquiring new financial interests) indicating whether you have engaged in outside activities at any time during the fiscal year.
Respond to the question on the COI SMART disclosure about interacting with a foreign entity to learn whether you are/are planning to become:
- An owner, founder, or manager of a foreign entity.
- An employee of a foreign entity.
- A consultant or independent contractor of a foreign entity or government.
- An operator of a laboratory or research facility in a foreign country.
- An investor in a foreign entity.
- A participant or financial sponsor of research conducted in a foreign country.
Conflict of Commitment (COC) *University Policy #500.07. This policy ensures disclosure and appropriate vetting of external activities to identify and remediate conflicts of commitment. All external activities that involve working with a foreign government or entity must receive prior written approval from the Supervisor and the Provost (or the Provost’s designee) before engaging in the activity.
Before engaging, complete a request *Participate in External Activity. Per policy, external activities include but are not limited to:
- Holding a paid or unpaid position such as founder, partner, employee, faculty member, or board member.
- A participant or member of a Governing Board or Scientific Advisory Board of a foreign entity.
- Read more illustrative case examples.
External Disclosures & Procedures:
When submitting applications for federal grants, list all foreign affiliations in the Biographical Sketches and Other Support sections, identify any changes in each annual progress report, and close out summaries. According to the NIH policy, this includes but is not limited to:
- Collaborations with investigators at a foreign site anticipated to result in co-authorship.
- Use of facilities, research materials, or instrumentation at a foreign site.
- Receipt of financial support or resources from a foreign entity.
It is expected that professional commitment of time and intellectual input is in support of Jefferson. When applying for federal grants, you need to be transparent about any affiliations with foreign entities. Only by your full disclosure will Jefferson be in compliance with federal regulations and be able to advise, assist, and protect you and your work.
For more information contact: Theodore F. Taraschi, PhD, Senior Associate Provost for Research Conduct and Compliance