Financial Disclosure For Externally Funded Projects

At the time of submitting an external funding proposal for approval by PSU officials (i.e., department chair, dean, Vice Provost for Research), 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:

• those that would reasonably appear to be directly and significantly affected by research or activities funded or proposed for funding, or
• those in entities whose financial interests would reasonably appear to be directly and significantly affected by such activities.

The financial disclosure should be a memorandum from the PI and/or Co-PI to the department chair and should accompany the proposal and the Proposal Internal Approval Form (PIAF). If the PIs and Co-PIs decide that no financial disclosure is required, then no memorandum is needed. Their signatures on the PIAF indicate that they are in compliance with the PSU Policy on Financial Disclosure. Additionally, 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.

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). The term does not include salary, royalties or other remuneration from the institution (PSU); or any ownership interests in the institution, if the institution is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program; income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;income from service on advisory committees or review panels for public or nonprofit entities; or financial interests in business enterprises or entitites if the value of such interests does not exceed $10,000 or represent more than a 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's spouse/partner and dependent children.

Review at two levels of supervision is required. The financial disclosures will be reviewed by the PI's and Co-PI's unit supervisor (usually the department chair) and by the dean of the college or school. For units which do not have departments, financial disclosures will be reviewed by the dean and by the Associate Vice Provost for Research. The reviewer(s) 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 reviewer(s) 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 reviewer(s) must indicate in a memorandum to the Vice Provost for Research 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 reviewer(s) must notify the Vice Provost for Research in writing.

Memoranda from the PIs/Co-PIs and the reviewer(s) must accompany the PIAF to the Office of Research and Sponsored Projects, and the Vice Provost for Research will be responsible for verifying compliance. The Vice Provost for Research is responsible for notifying the NSF or the PHS or other agencies of cases in which conflicts of interest cannot be satisfactorily eliminated.

The Vice Provost for Research will forward to the Associate Vice Provost for Sponsored Research a copy of the PIAF and all memoranda pertaining to financial disclosures and actions taken to eliminate actual and potential conflicts of interest. The Associate Vice Provost for Sponsored Research 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 later of 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 and following.