Outside Interests

Why do OI disclosures matter? 

In addition to the increased federal scrutiny regarding foreign influence on U.S. research, ensuring that persons involved in sponsored projects disclose outside interests is important for the following reasons: 

Compliance:  Researchers have to demonstrate that they adhere to applicable state and federal regulations that were designed to protect intellectual integrity and accuracy, similar to IRB (Human Ethics) and IACUC compliance.  

Credibility is at stake:  Research and sponsored projects should be as objective as possible, not only to uphold high ethical standards, but to maintain public trust. The reputation of the principal investigator and institution could be irreparably ruined through a public relations fiasco. 

Fines or loss of funding:  Failure to disclose can result in fines from thousands to millions of dollars, and grants can be suspended. 

Loss of employment:  Principal investigators who fail to disclose could be fired or forced to resign, and the conditions of which could make finding a new position difficult. 

Inability to publish:  Researchers found to be in noncompliance may be barred from submitting work to research journals for a period of time. 

Investigation:  Federal agencies employ inspectors to conduct investigations if there are reports of research misconduct or noncompliance. Agency investigation is an unpleasant experience akin to being audited. 

Requirements for Principal Investigators, Co-Principal Investigators and other Key Personnel 

Prior to proposal submission and release of award funds by OSP, investigators should complete CITI training and submit a Research-based Disclosure through the Cayuse Outside Interest Module. (For more information on Cayuse OI, click here) 

Proposals, whose sponsor is Department of Health and Human Services (DHHS)/Public Health Service (PHS) department or any agency of DHHS, National Science Foundation (NSF), United States Department of Agriculture, U.S. Department of Energy, U.S. Department of Defense, and National Aeronautics and Space Administration (NASA) must complete CITI training and submit a Cayuse Research-based disclosure for the project prior to release of funds to ensure compliance with federal regulations. 

• Complete CITI Conflicts of Interest Training (link here) 

• Complete the Research-based disclosure in the Cayuse Outside Interests Module 

What is a Financial Interest and Significant Financial Interest (SFI)?

A financial interest is any economic stake that an employee or their family members hold that might affect or appear to affect the employee's ability to perform their duties impartially and in the College's best interest. This includes ownership in stocks, bonds or other forms of securities, as well as income from employment, consulting fees and honoraria. It also encompasses interests in intellectual property rights, such as patents or copyrights, that could benefit financially from the employee's professional actions or decisions. 

A significant financial interest (SFI) is a specific subset of financial interests that are substantial enough to raise concerns about conflicts of interest. An SFI is typically defined by thresholds outlined in the policy, which could include, but are not limited to: 

• Income exceeding $5000 from any entity in the past 12 months, such as salary, consulting fees or honoraria. 

• Equity interests in publicly traded entities that exceed a specific value or percentage ownership. 

• Any equity interest in non-publicly traded entities, regardless of its value. 

• Intellectual property rights and interests that have generated income or are likely to do so.  

*SFIs must be disclosed to the WP to ensure they do not compromise, or appear to compromise, the integrity of the employee’s professional duties and WP's operations. 

CHIPS & Science Act of 2022 and International government talent recruitment program 

International government talent recruitment programs are in general a legitimate means that governments use to recruit science and technology professionals or students, and WP researchers may participate in them with prior approval of supervisors (Outside Activities Form). These activities primarily involve open and reciprocal exchange of scientific information aimed at advancing international scientific understanding.  

However, federal funding agencies are expressly prohibiting researchers from participating in Malign Foreign Talent Recruitment Programs (MFTRPs), as required by the Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act of 2022. The prohibition broadly includes institutions, individual investigators, contractors, and other key personnel. WP now prohibits researchers from participating in MFTRPs.  

Additional guidance and complete definitions are available in the Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs, published in February 2024.