Resources for Disclosure of Outside Interests

Disclosure of Outside Interests and International Collaboration

Given recent federal statements and guidance documents regarding U.S. research and the potential of foreign influence, our office has collected the resources listed below to assist researchers’ understanding of current requirements for disclosure of outside interests and foreign collaborations.

At the same time, we want to emphasize the university’s continued commitment to diversity and inclusion as reflected in Northeast Ohio Medical University’s guiding statement for the Office of Diversity, Equity, and Inclusion:

NEOMED embraces diversity, equity and inclusion values that create a working and learning environment grounded in respect and collegiately of all. The University views diversity as a commitment to recognizing and appreciating the variety of characteristics that make individuals unique — diversity encompasses race, culture, ethnicity, gender, socio-economic status, religion, age, sexual orientation, gender identity, gender expression, disability and military/veteran status.Integrity and transparency are also core values of our university. We all must follow government regulations and university policies. As always, our university strives to make the university community aware of regulations related to research, as well as to provide guidance on compliance.

Federal agencies’ statements and guidance

National Institutes of Health (NIH): Notice 19-114;
National Science Foundation (NSF): Dear Colleague Letter 19-200; and proposed revisions to the Proposal and Award Policies and Procedures Guide (PAPPG);
S. Department of Defense (DOD): March 2019 Memorandum; and
S. Department of Energy (DOE): Order DOE O 486.1. The department also is reported to be considering an additional policy applying to grant recipients.

Federal agencies’ resources

Performance of work outside the United States (for proposals and progress reports)

NIH Research application instructions (see instructions related to international collaborators and foreign component);
NIH Research Performance Progress Report (RPPR) instructions (see instructions related to participants affiliated with a foreign organization; award budget being spent in a foreign country; or foreign component);
NSF proposal instructions on foreign organizations; and
NSF Research Performance Progress Report (RPPR) instructions (see instructions related to participants or partner organizations).

Other/Current and pending support

Biographical sketches/outside affiliations

Confidentiality of peer review

NEOMED’s relevant policies and resources

Conflicts of Interest

The NEOMED policy on financial conflicts of interest in research is located in the university’s Policy Portal.

The NEOMED policy on conflict of interests requires faculty to disclose any outside financial interest and the acceptance of any gifts, favors, or anything of value, by the individual or the individual’s spouse, dependent children, domestic partner, or any other dependent person who is a member of the same household as the individual, that directly or indirectly might influence or appear to a reasonable person to influence the individual’s responsibilities as a member of the University.

Faculty engaged in research are required to submit a Financial Conflict of Interest in Research Disclosure Form to NEOMED’s Institutional Officials with each new grant application (and to update it annually during the period of the award, or within thirty (30) days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new Significant Interest Financial Interest.

In this policy, ‘financial interest’ is anything of monetary value, whether or not the value is readily ascertainable. Examples of financial interests include the following: income; honoraria; consulting fees; advisory board fees; membership on a speaker’s bureau; remuneration; gifts or other emoluments; “in kind” compensation; and travel expenses and reimbursement.
Intellectual Property

The NEOMED Intellectual Property Policy is found in the Policy Portal.

The University’s faculty, staff, and students, as part of their normal professional activities, conduct research that may be of significant benefit to the public and that merits development of its commercial potential. The University supports such research from its own resources; corporations, foundations, and governmental entities also provide funding for such research (“external funding”). The sponsors of external funding impose a variety of contractual terms on the University in connection with their financial support, including requirements regarding disclosure of matters pertaining to the research supported by external funding and allocation of the rights to inventions and discoveries produced by such research (collectively such inventions and discoveries are referred to herein as “applications”). These contractual terms are especially important in connection with those applications with commercial potential. The University owns title to intellectual property except as otherwise contractually provided, whether such contractual provisions are associated with external funding or otherwise. This ownership helps further the University’s academic mission in that it promotes research, the dissemination of knowledge, and the well being of society in general. University ownership of intellectual property expedites commercialization, and ownership is often a condition of external funding; indeed the Bayh-Dole Act requires it for research funded by federal agencies.