NSF-NIH Disclosure Quick Reference Guide

DISCLOSURE TYPE	PACS	NSF			NIH
DISCLOSURE TYPE	COI	Bio	C&P	FCOI4	Bio	OS	FCOI⁵
*Common Activities and Relationships (paid and unpaid) related to professional/academic/scientific expertise*
BU positions		✔			✔
Appointments and positions at an external entity, whether full-time, part-time, or voluntary	✔	✔		✔	✔1		✔
Education and training		✔			✔
Consulting, advising, or other services for external entities	✔		✔	✔		✔	✔
Expert witness service	✔			✔			✔
Serving on government or industry review boards or panels	✔			✔			✔
Research at or laboratory work for an external entity	✔		✔	✔		✔	✔
Editorial work for journals	✔			✔			✔
Grant review (see exemptions)²	✔			✔			✔
Leadership role in a company or professional society	✔	✔		✔	✔		✔
Speaking compensation (see exemptions)	✔			✔			✔
Reimbursed or sponsored travel not related to BU responsibilities (see exemptions)²	✔		✔3			✔	✔
*Other International Engagements related to professional/academic/scientific expertise*
Foreign talent programs	✔		✔	✔		✔	✔
Foreign support for trainees in your lab			✔			✔
Academic recruitment on behalf of a foreign entity	✔			✔			✔
Consulting or advisory service for a foreign entity or government	✔		✔	✔		✔1	✔
Engagement with foreign entities or governments that are part of an agreement between BU and that entity			✔			✔1
Research support or engagement with a foreign entity outside of a BU agreement	✔		✔	✔		✔	✔
Grant review for a foreign government or entity	✔			✔			✔
Travel reimbursed or sponsored by a foreign entity	✔		✔3			✔
*Ownership Interests related to professional/academic/scientific expertise*
Ownership (stock, options, etc.) in a company	✔			✔			✔
Income related to the sale of ownership in a company	✔
Venture or capital financing	✔			✔
Royalties, milestones, and option fees paid by a third party	✔			✔		✔
Startup company based on non-organization-licensed IP	✔		✔	✔			✔
*Gifts, Grants, Contracts, and Other External Support (funded and in-kind) related to professional/academic/scientific expertise*
Financial or in-kind gifts made directly to discloser by a third party in support of professional, academic, scientific, or research activity	✔		✔			✔
All projects currently under consideration from whatever source, and all ongoing projects, irrespective of whether support is provided through BU, another organization, or directly to the individual, and regardless of whether or not they have monetary value			✔			✔
In-kind contributions not intended for use on the project/proposal being proposed and have an associated time commitment			✔			✔
Students, postdocs, or other researchers funded by an external entity			✔			✔
Startup packages from organizations other than BU			✔			✔

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¹ Per : Supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts/agreements are not in English, recipients must provide translated copies.

² There are three main categories of exemptions: 1) You do not need to disclose payments received through BU such as BU salary or travel reimbursements; 2) You do not need to disclose personal activities unrelated to your academic and professional expertise; 3) There are several regulatory carve-outs for types of activities that do not have to be reported if they take place with certain types of U.S. entities, such as presentations or trainings you provide to U.S. academic institutions.

³ Travel supported/paid by an external entity to perform research activities with an associated time commitment is required to be reported, support to attend a conference or workshop is not required to be reported.

4 NSF FCOI disclosure thresholds are: disclosure of interests of self, spouse, and children that pose a potential conflict of interest, generally with a threshold of $10,000. Private equity is disclosable regardless of value.

5 NIH FCOI disclosure thresholds are: disclosure of interests of self, spouse, and children that are related to your BU responsibilities, generally with a threshold of $5,000. Private equity is disclosable regardless of value.

Contact hbragg@binghamton.edu for questions regarding PACS COI requirements. Contact osp@binghamton.edu for questions regarding NSF and NIH requirements.

/research/division-offices/research-compliance/conflict-interest.html

/research/division-offices/sponsored-programs/proposal-development.html

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