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At the time of submitting an external funding proposal each principal investigator (PI) and co-principal investigator (Co-PI) must disclose all significant financial interests (including those of the PI's and Co-PI's spouse/partner and dependent children), including:
The term significant financial interest means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights) that exceed $10,000 annual income or five percent (5%) equity, whichever is less. The term does not include salary, royalties or other remuneration from Western Oregon University.
The financial disclosure should be a memorandum from the PI and/or Co-PI to the division chair and should accompany the WOU Proposal Routing form. If the PIs and Co-PIs decide that no financial disclosure is required, then no memorandum is needed. It is the responsibility of the PIs and Co-PIs to update their financial disclosures throughout the duration of an application and an award as new reportable significant financial interests arise.
If a financial disclosure memorandum is received it will be reviewed by the division chair and by the college dean or agency director. The reviewers must determine whether an actual or potential conflict of interest exists and implement actions to eliminate the conflicts of interest. An actual or potential conflict of interest exists when the reviewers reasonably determine that a significant financial interest could affect the design, conduct, or reporting of the research or educational activities funded or proposed for funding. The reviewers must indicate in a memorandum to the Vice President for Academic Affairs whether they found a conflict of interest and, if so, the actions which will be implemented to eliminate the actual or potential conflict of interest. Actual and potential conflicts of interest must be eliminated prior to funding by the sponsoring agency. If changes in reportable, significant financial interests occur throughout the duration of an application or an award, the reviewers must notify the Vice President for Academic Affairs in writing.
Memoranda from the PIs/Co-PIs and the reviewers must accompany the WOU Proposal Routing Form to the Office of Institutional Research and Sponsored Projects (OIRSP), and the OIRSP Director will be responsible for verifying compliance. The OIRSP Director is responsible for notifying the NSF or the PHS or other agencies of cases in which conflicts of interest cannot be satisfactorily eliminated.
The Office of Institutional Research and Sponsored Projects will be responsible for maintaining records of all financial disclosures and all actions taken to eliminate actual or potential conflicts of interest until at least 3 years after the the termination or completion of the award to which they relate, or the resolution of any government action involving the records.
Collaborators from other institutions must either comply with this policy or provide a certification that their institutions are in compliance with Federal policies regarding investigator significant financial interest disclosure and that their portion of the project is in compliance with their institutional policies.
Sanctions: Failure to comply with this policy may result in sanctions for cause ranging from a warning to dismissal in accordance with OAR 580-21-320.
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