Albert Einstein College of Medicine requires disclosure of financial interests (FI) of any value, including salary or any remuneration for services. Additionally, the disclosure must include FI of a related party (spouse, domestic partner, or dependent child). All disclosures must be complete, timely and truthful.
Investigators engaged in PHS-funded research or human subjects research (regardless of funding) must submit COI disclosures on at least an annual basis. However, a COI disclosure is considered up to date if it is submitted within six (6) months of the COI review date.
Investigators must also update their COI disclosures within thirty (30) days of acquiring any new remuneration, establishment of a new role, or acquisition of any new Intellectual Property. Other events which require updated disclosures include:
- Submission of a grant application to the Office of Grant Support (COI review must be completed before the expenditure of any grant funds);
- Submission of a human subjects’ research protocol;
- Filing for a patent or clinical trial agreement;
- Establishment of a contract with a commercial entity as detailed by Einstein’s Office of Biotechnology and Business Development.
Information Pertaining to Conflict of Interest Disclosure
The following definitions are derived from the Code of Federal Regulations, 42 CFS 50.603, https://www.ecfr.gov/current/title-42/chapter-I/subchapter-D/part-50/subpart-F. Please familiarize yourself with these definitions and gather the relevant financial documents needed to initiate or update your conflict of interest disclosure form:
Financial interest means anything of monetary value, whether or not the value is readily ascertainable.
Disclosure of significant financial interests means an Investigator's disclosure of significant financial interests to an Institution.
Financial conflict of interest (FCOI) means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research or human subject research.
Institution means any domestic or foreign, public or private, entity or organization (excluding a Federal agency) that is applying for, or that receives, PHS research funding.
Significant financial interest means:
- A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's institutional responsibilities:
- (i) With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;
- (ii) With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator's spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
- (iii) Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
- Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities; provided, however, that this disclosure requirement does not apply to travel that is reimbursed or 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.
See Einstein Comprehensive COI Policy for additional information: New Comprehensive Conflict of Interest Policy
User requesting COI access to register as a new user or update a disclosure please contact COI@einsteinmed.edu
Replies from the COI e-mail account occur during business hours only.
(06/07/2018)