DISCLOSING SIGNIFICANT FINANCIAL INTERESTS
SUBRECIPIENT INVESTIGATORS on PHS or NSF FUNDED PROJECTS
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 guidelines before completing the disclosure form.
Disclosure Requirements: You have been identified as a subrecipient investigator subject to the University of Northern
Colorado’s (UNC) Financial Conflict of Interest policy. As an investigator on a proposed Public Health Service or National
Science Foundation project, please disclose your significant financial interests (SFI) aggregated with those of your spouse
and dependent children, on the attached disclosure form. These disclosure requirements are in compliance with PHS
regulations 42 CFR Part 50 Subpart F or Chapter IV of the NSF Award and Administration Guide, as applicable.
Disclosures must be made:
o For PHS and NSF funded projects – an initial disclosure must be provided prior to UNC submitting the proposal.
o For PHS and NSF funded projects – an update for disclosing new significant financial interests must be provided
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 a subaward is made)
o For PHS funded projects – an annual update must be provided during the period of the subaward. Annual
disclosures are due between November 1 and November 31 regardless of when you made your initial disclosure or
disclosed new SFIs.
NOTE: UNC will not submit a proposal until disclosures from all investigators on the project have been received.
Training Requirement for PHS funded projects: If a proposed PHS funded project is awarded, you are required to
complete conflict of interest training before engaging in work related to the PHS funded award and again every four years
during the period of the subaward. 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 when on
the CITI website, complete the Conflict of Interest modules. You will need to affiliate your training with the University of
Northern Colorado so that we receive your training certification.
If you have completed the CITI Conflict of Interest training within the past four years, you may provide a copy of your
CITI Completion Report with your significant financial interests disclosure form in lieu of taking the training again at this
time.
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 the Subrecipient if you (or your spouse or dependent children, as
applicable) are currently employed or otherwise appointed by the Subrecipient;
o Income related to intellectual property rights assigned to the Subrecipient 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, or could be perceived to be, directly related to
your employment responsibilities or to the work you will be performing in collaboration with UNC on the identified
project.
Please address questions regarding your disclosure to Sherry May at 970-351-19102 or sherry.may@unco.edu.
