DISCLOSING SIGNIFICANT FINANCIAL INTERESTS
FOR UNC INVESTIGATORS
The University of Northern Colorado’s Financial Conflict of Interest Policy is found in the University Regulations Article 3,
Part 4, Section 3-3-402(1), and the implementing procedures are found at http://www.unco.edu/osp/policies/fcoiproc.pdf.
Please review those documents and read the following before completing the disclosure form.
Disclosure Requirements: As an investigator on an externally funded project or a proposal for external funding, you are
required disclose your significant financial interests (SFI), aggregated with those of your spouse and dependent children,
on the attached disclosure form.
o The Office of Sponsored Programs (OSP) must have disclosures prior to submitting your proposal for external
funding.
o You are also required to submit a disclosure update during the period of any award funded by PHS or NSF (whether
direct or pass through funding) within 30 days of discovering or acquiring any new financial interest (including
those that may arise between the time the proposal is submitted and the time an award is made).
o You are also required to submit annual update disclosures during the period of any PHS funded award. These
annual updates are due between November 1 and November 30 regardless of when you made your initial
disclosure or disclosed new SFIs.
NOTE: UNC will not submit a proposal until all investigators (including any subrecipient investigators, if applicable) have
submitted disclosures to the Office of Sponsored Programs. The PI is responsible for ensuring that all other Investigators
submit their disclosures.
Training Requirement on PHS funded projects: Investigators on PHS funded awards are required to complete conflict of
interest training before engaging in work related to the PHS funded award, and again every four years during any PHS
funded award. The required training is available on-line through the Collaborative Institutional Training Initiative (CITI).
To access CITI, follow the directions at: http://www.unco.edu/osp/ethics/citi.html; and on the CITI website, complete the
Financial Conflict of Interest modules. You will need to affiliate your training with the University of Northern Colorado so
that we receive notification from CITI when you have completed the training.
DISCLOSURE DEFINITIONS
o Remuneration includes all salary and any payment for services not otherwise identified as salary, such as
consulting fees, honoraria, and paid authorships.
o Equity interest includes any stock, stock option, or other ownership interest with the value determined through
public prices or other reasonable measures of fair market value.
DISCLOSURE EXCEPTIONS – DO NOT INCLUDE the following when disclosing financial interests:
o Salary, royalties, or other remuneration paid by UNC if you (or your spouse or dependent children, as applicable)
are currently employed or otherwise appointed by UNC;
o Income related to intellectual property rights assigned to UNC or to agreements to share in royalties related to
such rights;
o Income from investment vehicles such as mutual funds and retirement accounts for which you, your spouse and
dependent children do not directly control the investment decisions made in such vehicles
o Income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government
agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a
medical center, or a research institute that is affiliated with an institution of higher education as defined at 20
U.S.C. 1001(a)
o Income from service on advisory committees or review panels for a Federal, state, or local government agency,
an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical
center, or a research institute that is affiliated with an institution of higher education as defined at 20 U.S.C.
1001(a)
You need to report only those Significant Financial Interests that are directly related to your responsibilities as an employee of the
University of Northern Colorado.
Please address questions regarding FCOI disclosures to Nicole Morse at 970-351-1910 or nicole.morse@unco.edu.
05.2016