Investigator Financial Disclosure Policy
(Applicable to all Sponsored Project Proposals)
What is Required?
Federal regulations require institutions to have policies and procedures in place that ensure that investigators disclose any significant financial interest that may present an actual or potential conflict of interest in relationship to externally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding, and institutions must develop specific mechanisms by which conflicts of interest will be satisfactorily managed, reduced, or eliminated prior to award or acceptance of an award. Middlebury College adopted a Conflicting Financial Interest Policy on September 19, 1995.
*If a new reportable significant conflict of interest arises at any time during the period after the submission of the proposal through the period of the award, the filing of a disclosure is also required.
Who is covered?
"Investigator" means the principal investigator/project director, co-principal investigators, and any other person at the College who is responsible for the design, conduct, or reporting of research, educational, or service activities funded, or proposed for funding by an external sponsor. In this context, the term "investigator" includes the investigator's spouse or domestic partner and dependent children.
What must be disclosed?
Each investigator shall disclose all significant financial interests:
(i) that would reasonably appear to be affected by the research or educational activities funded, or proposed for funding, by an external sponsor; or
(ii) in entities whose financial interests would reasonably appear to be affected by such activities.
What is covered?
"Significant financial interests" means anything of monetary value, including,but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights). The term does not include:
1. Salary, royalties, or other remuneration from the College;
2. An equity interest that when aggregated for the Investigator and the Investigator's spouse or domestic partner and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a five percent ownership interest in any single entity; or
3. Salary, royalties or other payments that when aggregated for the Investigator and the Investigator's spouse or domestic partner and dependent children over the next twelve months, are not expected to exceed $10,000; or
4. Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; or
5. Income from service on advisory committees or review panels for public or nonprofit entities.
Provided, however, that the exclusions in the first three items shall not apply if the compensation or transfer of an equity interest is conditioned upon a particular outcome in a sponsored research project.
Disclosure Procedures:
1. All investigators must disclose their significant financial interest utilizing the form on the reverse side and attaching all required supporting documentation. The completed Disclosure Form must be submitted with the proposal and College Grant Proposal Endorsement Form ("blue sheet") to the Comptroller's office following normal College procedures. Supporting documentation should be submitted in a sealed envelope marked confidential.
2. In accordance with Federal regulations, a complete disclosure must be made by investigator(s)prior to submission of the proposal.
3. All conflicts of interests must be resolved prior to expenditure of any funds. The Comptroller may require written documentation for the plans to resolve conflicts of interest.
Significant Financial Disclosure Form