Federal Policy - Disclosure
¡Required for all NSF and PHS funding applications ¡Applies to those involved with the design, conduct, or reporting of research
¡Related financial interests must be disclosed
¡
USC requires disclosure of potential conflicts for all sponsored programs (see PAP)

More formalized process for NSF and PHS projects (form)
Project by project
Annual basis (w/updates)

Who – Usually those “listed” as key personnel including:
•Co-PIs
•Research Associates/Post Docs
•Technicians

Whenever the work to be performed under the sponsored project and the results of the undertaking could reasonably be expected to have an impact on a financial interest –

The financial interest is related to the sponsored project and MUST be disclosed
Financial Interest” related to a sponsored project
Will manufacture or commercialize a product that will predictably result from the project
Results would be relevant to the development, manufacture, or improvement of a product
Income from consulting > $10,000
Result in subcontract, lease of property or procurement
Referral of participants or collaborations