Frequently Asked Questions

Please review the following information about conflict of interest and financial disclosure for UB investigators if you have questions about when and how to file.

On this page:

Who is considered an investigator?

UB follows federal policies, asking investigators to file financial disclosure statements annually at the very least. Investigators are those persons who, regardless of title or position, design, conduct or report research. They have the authority to make independent decisions about the direction of the research and subsequent conclusions drawn from the results.

You don't need to file if you are a non-investigator staff member. These persons are directed by the investigator(s) and have  well-defined roles and responsibilities for implementing research projects.

To whom should I disclose my financial interests?

You submit your financial disclosure statement online through the COI Risk Manager. The system forwards the disclosure to your dean's office and those persons responsible for review of financial disclosure statements.

When should I disclose my financial interests?

UB's annual filing deadline is Nov. 30.

For Public Health Service funded research (principally NIH), you must submit your disclosure:

  • Prior to applying for PHS funding; and
  • Within 30 days of discovering or acquiring a new significant financial interest; and
  • Annually thereafter.

What federal agencies fall under the 2011 Public Health Service (PHS) conflict of interest regulations?

All components of the PHS including:

  • Agency for Healthcare Research and Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Centers for Disease Control and Prevention (CDC)
  • Food and Drug Administration (FDA)
  • Health Resources and Services Administration (HRSA)
  • Indian Health Service (IHS)
  • National Institutes of Health (NIH) and all of the Institutes within the NIH
  • Substance Abuse and Mental Health Services Administration (SAMHSA)

What happens if I acquire significant financial interests during the award?

Within 30 days of discovering or acquiring a significant financial interest (e.g., through purchase, marriage or inheritance), you must submit an updated disclosure using Click COI.

UB's policy is consistent with the 2011 revised PHS regulations for investigators participating in NIH-funded research.

Learn more about the PHS financial conflict of interest policy.