Guidance for Disclosers
- Requirement for and frequency of filing a disclosure form
- Conflict Management
- What do I need to disclose?
- Completing the MyDisclosures form
- What happens after the form is submitted?
Requirement for and frequency of filing a disclosure form
Does MyDisclosures satisfy reporting requirements for grants, contracts or other funding applications for federal or other agencies?
No. MyDisclosures is used to report information to the University of Pittsburgh and UPMC. It does not report information to any funding agency. Reporting an activity in MyDisclosures does not satisfy any requirements to disclose information about your outside relationships and activities in grant, contract or other funding applications to federal or other funding agencies.You must still disclose any required information on all funding applications as required by the sponsoring agency.
Why do I have to submit a disclosure form?
University faculty and staff members are encouraged to engage in outside activities consistent with our mission to share knowledge with industrial and governmental organizations1. Such activities, however, should not interfere with University duties or distort professional judgment. To ensure transparency and compliance with University policies and applicable federal regulations, you are asked to disclose certain information about your activities outside of the University that relate to your work at the University, or the University’s educational, research, service or other missions.
I have never needed to file a disclosure before. Why am I being asked to now?
MyDisclosures is different from the prior system. It includes questions about your outside financial interests, as well as your time commitments to outside organizations. Previously, time commitments were discussed informally and directly between University personnel and their department chair or supervisor. Now, with MyDisclosures, personnel and their supervisors can easily report, track and review time commitments, as well as financial interests, electronically in one place.
How often do I need to complete a conflict disclosure form?
You must submit a disclosure form at least annually, even if you have no outside activities to report. You must also update your form as often as necessary throughout the year to keep your information up to date.University policy and federal regulations require that you update your conflict disclosure within 30 days of acquiring or discovering a new outside interest.
Can I complete a paper version of the disclosure?
No. MyDisclosures is entirely electronic and paper copies of the form are not available. You will complete your disclosure electronically and the system will automatically send your form to your supervisor or department chair for review. You will no longer need to print a signature form for your supervisor to sign.
Do I still have to complete a form and know about conflicts policies if I do not engage in any professional activities outside of my University responsibilities and have nothing to report?
Yes. Even if you do not currently engage in any outside activities and you answer “no” to every question you see, you must still submit a disclosure. MyDisclosures will show you only the questions that you are required to answer. As a University employee, you are responsible for complying and being familiar with all University policies. It is important that you regularly submit disclosures and stay aware of University policies governing conflicts of interest and commitment.
This sounds more complex than the previous form. Will I be doing more reporting?
Not overall. The financial reporting is just the same, but we are including questions about time commitments that would previously have been part of discussions between you and your chair/supervisor or included in your annual evaluation. There will now be a single place and point in the year at which you make disclosures.
If it is determined that I have a conflict of interest, how will it be managed?
Each person’s situation is different. Conflicts are managed on a case-by-case basis to ensure that the unique needs of the individual and the University are met. The Conflict of Interest (COI) Committee, with the support of the COI Office, is responsible for managing conflicts of interest. If it is determined that you have a conflict, you may be asked to enter into a Conflict Management Plan (CMP) that will manage, reduce or eliminate the conflict, as needed. A CMP may include mandatory disclosure of your outside interest in publications, abstracts or funding applications, monitoring of research by an independent oversight committee, disclosure to human subjects, students or other investigators and research team members, restrictions on serving as a Principal Investigator (“PI”) or, in certain severe cases, the elimination of the conflicting interest.
If it is determined that I have a conflict of commitment, how will it be managed?
Each person’s situation is different. Conflicts are managed on a case-by-case basis to ensure that the unique needs of the individual and the University are met. In the rare case that your department chair or supervisor identifies a conflict of commitment between your University duties and your outside activities, they will work with you and the dean of your school, as necessary, to take the appropriate steps to manage it.
Where can I get more information about conflict of interest and conflict of commitment requirements?
For more information about conflicts of interest and commitment, including the definition of a “Significant Financial Interest” or “SFI”, you can visit the COI Website. Please review the Conflict of Interest for Research Policy RI01 (formerly Policy 11-01-03).
What do I need to disclose?
Do I have to disclose information about my immediate family?
Yes. You will be asked to disclose the outside financial interests of your spouse or domestic partner and your dependent children that relate to your institutional responsibilities at the University. You will also be asked if your family engages in University research, or if they are a party to a contract with the University, such as selling or leasing property to the University.
What time period is covered by the disclosure?
The disclosure should include all outside interests and relationships you had, and activities you performed during the previous 12 months and those that you reasonably anticipate will occur in the next 12 months. For example, a disclosure filed in July 2020 will include your interests from July 2019 and those that you reasonably anticipate having through July 2021.
Do I have to report information about work I do on behalf of the University for or with outside entities?
No. You do not need to disclose work you perform for an entity outside of the University if you performed the work as part of your University responsibilities.If the contract underlying your services is an agreement between the entity and the University that was negotiated through the Office of Sponsored Programs, you do not need to disclose it.
Do I need to disclose personal consulting services I perform for for-profit companies, even if I did not get paid or receive direct payment for the services (e.g.: the company made a gift to my department instead of paying me)?
Yes. You must report all of your outside activities, even if you did not receive payment for them. Report any activities, relationships or interests you have that were not coordinated or negotiated by the University’s Office of Sponsored Programs.
Do I need to disclose personal consulting services I perform for non-profit companies, such as service on committees or governing boards of professional organizations, even if I am not paid for these activities?
Yes. Even if you did not get paid, all consulting services you provide for non-profit organizations must be disclosed if they relate to your individual responsibilities at the University.
What federal government work do I need to disclose?
You do not need to report work you perform on grant or other panels evaluating applications for research funding from the United States government (e.g., from NIH, NSF, NASA, etc.)
You should disclose work that you performed or expect to perform for the US federal government that give, or could be perceived to give, the University an unfair competitive advantage in securing or that could bias judgment on a government contract. Consider services you performed as an employee, independent contractor, or consultant for the federal government or for any other entity.
Organizational Conflicts of Interest (OCIs) can result when the nature of the work someone at the University performs for the federal government creates an actual or potential conflict of interest for the University on a future Federal award.OCIs can occur when someone at the University prepares or writes specifications for federal funding opportunities, has access to non-public information that provides a competitive advantage, or when someone is evaluating or assessing any work performed by others at the University. For more information about OCIs, visit the COI website and review the University’s OCI policy.
Completing the MyDisclosures Form
Do I have to select which form to complete?
No. Unlike the prior disclosure system, MyDisclosures will only show you the questions you have to answer based on your position(s) at the University or UPMC. At the beginning of the form, you will indicate whether you employed by the University and/or UPMC and whether you receive PHS funding. Your responses to the questions will automatically generate the rest of the questions you need to complete on your form. You will only be asked to provide information specific to your role at Pitt and/or UPMC.
Why is this a joint University and UPMC disclosure module?
Many University faculty members and staff are dually employed, dually appointed or conduct research for both Pitt and UPMC. Having a single forum for disclosure greatly simplifies obligations for them. Additionally, a single disclosure form enhances the ability of University offices, such as the Office of Research Protections and the Office of Sponsored Programs, to ensure compliance with applicable University policies, federal laws and regulations.
I am dually employed. Do I have to fill out separate forms for the University and UPMC as I did before?
No. MyDisclosures satisfies both your University and UPMC conflict disclosure requirements. You no longer need to complete the UPMC form in My HUB or the COI Superform.
Who should be listed as my supervisor?
The primary supervisor listed on your disclosure form should be the person who completes your annual performance review. This may be your department chair or another supervisor, depending on your particular circumstances.
Do I have to list a secondary supervisor?
A secondary supervisor is one who reviews your disclosure in addition to your primary supervisor. Some disclosers may have more than one supervisor who asks to review their disclosure. For example, if you work in one of the University’s centers or institutes, the director may ask to review your disclosure. If you do not have a secondary supervisor, you will leave the section blank.
What details do I have to report about each interest?
You will be asked to report:
- Name of the entity with which you have a relationship;
- Time you spent on the activity;
- Amount earned from an activity or the value of the relationship, if it exceeds the applicable threshold for your circumstances3;
- Type of relationship or interest you have – equity, consulting and professional activities, sponsored or reimbursed travel, intellectual property rights, management or officer positions and other benefits;
- Whether you have a conflict management plan (CMP) for your relationship with the entity;
- Whether you conduct research at the University or UPMC that relates to your interests;
- Whether the entity is a foreign government entity, a foreign institute of higher education or affiliated with such foreign entities; and
- Whether you purchase products or services from the entity on behalf of the University or UPMC.
How do I calculate the amount I earned from an entity?
Each type of interest you have with an entity is valued and calculated separately. MyDisclosures will prompt you to enter them separately. For example, if you received consulting fees totaling $5,000 and the entity paid $5,000 for you to travel to a meeting, you will report each of these items separately. At the end of your form, you will be shown a summary table that adds the value of all of your interests together automatically.
If I have a financial interest in a company, do I need to report if that company employs any of my staff, students I supervise, or my trainees?
Yes. If you or a member of your immediate family has a financial interest in a company, and that company employs a University staff member, student or trainee that you oversee, you must report it on your form. You will need to report the number of days per year that the staff member, student, or trainee worked.
What happens after the form is submitted?
Who will see my disclosures?
Unless required by law or regulation, the University does not disclose the information gathered during the conflict of interest process with non-university employees. Your disclosures will be reviewed by your supervisor and will be used by the University to evaluate potential conflicts of interest and commitment.
What happens when I make a disclosure?
Your supervisor will review your disclosure to determine whether your activities or interest give rise to an actual or potential conflict of interest or commitment that can be evaluated and, if necessary, managed.
Does my department chair or supervisor still need to review my disclosure?
Yes. When you submit your disclosures, MyDisclosures will automatically send your form to your supervisor for their review. You will no longer need to print a signature form for your supervisor to sign.
As a supervisor reviewing disclosure forms, why do I see disclosure thresholds of $0, $5,000 and $10,000?
The disclosure threshold that a discloser sees on their form is based on whether they are dually employed by the University and UPMC and their research or other funding sources.
- $0 is the reporting threshold established by UPMC policy. Individuals employed by the University and UPMC will see a $0 disclosure threshold.
- $5,000 is the reporting threshold established by the Public Health Service (PHS) regulations.
- $10,000 is the reporting threshold established by University policy for all non-PHS funding agencies. It is also the threshold established by the National Science Foundation (NSF).
1 See Pitt Policy RI01 and Policy 02-06-01.
2,3 Your form will automatically prompt you with the correct amount based on your responses to questions at the beginning of the form.