Reporting significant financial obligations in UB research

UB follows federal policies, asking investigators to file financial disclosure statements annually. Investigators are those persons who, regardless of title or position, is responsible for the design, conduct, or reporting of 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. 

1. The investigator and a reviewer in their dean's office draft a conflict-of-interest (COI) management plan for the CIRC committee. This ensures the plan is developed with the investigator's input and that of someone familiar with their specific research culture.
2. CIRC reviews the draft plan or develops a management plan if needed.
3. At minimum, an approved plan requires full disclosure of any sponsor relationships to:
   • Colleagues on the study,
   • Research participants, and
   • In any publications or presentations

Investigators funded by the Public Health Service also must complete an online conflict of interest mini-course through CITI. 

All investigators must update their financial disclosure statements annually. UB's annual filing deadline is Nov. 1. 

All investigators must have a current financial disclosure on file prior to applying for extramural funding.

• Click COI will email notifications mid-September alerting individuals that they must complete their financial disclosure. A current annual financial disclosure must be completed prior to applying for extramural funding.
• Disclosures must also be filed within 30 days of discovering or acquiring a significant financial interest (e.g., through purchase, marriage or inheritance). Updating your financial disclosure is accomplished via Click COI.  

Submit your financial disclosure statement online through Click COI. Learn more below. 

You must update your financial disclosure within 30 days of discovering or acquiring a significant financial interest (e.g., through purchase, marriage or inheritance) via Click COI. 

Once a financial disclosure is updated it will be reviewed against current awards and/or IRB protocols to determine if there is a potential conflict of interest or not. If it is determined that there is a conflict of interest, a management plan must be developed and submitted to UB's Conflict of Interest Research Committee (CIRC) for approval. 

If YES: Could this work reasonably appear to be related to your institutional responsibilities?

If YES again, you need to disclose. 

If YES: Could this management position reasonably appear to be related to your institutional responsibilities?

If YES again, you need to disclose. 

If YES: Do your interests in the company reasonably appear to be related to your institutional responsibilities?

If YES: Does the combined value of your stock in and income from this company in the past 12 months exceed $5,000? 

If YES again, you must disclose.

If YES: Does this income reasonably appear to be related to your institutional responsibilities? 

If YES: Does the income exceed $5,000?  

If YES again, you must disclose.

If YES: Does your equity interest reasonably appear to be related to your institutional responsibilities? 

If YES again, you must disclose. 

If YES: Is this income from an entity other than SUNY or the Research Foundation of SUNY?

If YES again, you must disclose.

If YES: Was this travel related to your institutional responsibilities?

If YES: Was the travel paid for by an organization that is not a government agency, institution of higher education, academic teaching hospital, medical center or research institute affiliated with a higher education institution? 

If YES again, you must disclose.