When to Disclose?
All faculty and staff are required to disclose at least annually. This usually occurs during the annual disclosure process in February.
Other times disclosure is required:
- New significant financial interest. Faculty and staff who are involved in sponsored research are subject to research disclosure requirements, which require updates on a rolling basis within 30 days of acquiring (or becoming aware of) a new significant financial interest.
- New outside activity. If faculty or staff initiate a new outside activity that is related to their Northwestern responsibilities (e.g., a new freelance business that works with / is seeking to work with Northwestern) it is prudent to update your disclosure.
- Tip! This is also an opportunity to provide documentation or a summary of the conversation you had with your supervisor/chair/dean's office obtaining prior approval for the activity or discussing how the activity will be handled so that it does not detract from your Northwestern responsibilities.
Note: If updates are submitted outside of the annual process, that information will be saved and pre-populated for you during the annual process. It will not be necessary to enter the information twice.
Examples of when researchers need to update their disclosure:
Cumulative payments for the past 12 months from an entity exceed $5,000
The Conflict of Interest in Research policy, which is based on federal regulations, requires faculty and staff who are involved in research to update their disclosures if they receive more than $5,000 in cumulative payments from a single company over the previous twelve months.
- Consulting relationship with payments of $1,500 per engagement. Meetings in October and December of 2017, April and June of 2018. A disclosure update should be submitted within 30 days of the June meeting because the cumulative payment for the previous 12 months is now more than $5,000 (at $6,000).
A start-up company is formed
If a faculty or staff member is a founder or co-founder of a start-up company, and consequently is a part owner of the company, that relationship needs to be disclosed within 30 days of creating a legal entity.
While we understand that often companies exist "only on paper," because that paperwork creates a legal entity, legally, those companies exist. Ownership (including being co-founder of a company, having options in a company, or any other equity holding) in a non-publicly traded entity is considered to be a significant financial interest and disclosure is required within 30 days of acquiring that interest.
It may be decided, after discussion with the faculty or staff member, that the nascent company does not create a conflict of interest given its early stage, but the policy and regulations require disclosure of significant financial interests (SFIs), not only conflicts of interest.
What happens if disclosures are not submitted when required by policy?
If your annual disclosure is not completed during the annual disclosure period in February, the following repercussions may occur:
- Your supervisor and/or dean's office will be alerted to the fact that your disclosure was not submitted on time.
- If you are involved in research, and you have not updated in the last 365 days, you may not be able to submit new proposals, and new projects may not receive chartstrings until a disclosure is completed.
- If you are on active research projects from federal sponsors, Northwestern may not be able to invoice the sponsor for work performed on grants until a disclosure is completed.
New interest that requires an update
If a person who is involved in research does not submit an updated disclosure when they have a new significant financial interest, there is a risk that the University will need to conduct a retrospective review.
In the instance where someone involved in research has a new significant financial interest (SFI) that is not disclosed in a timely manner, and it is determined that that SFI is a conflict of interest with a research project, the University must review all research activity on that project (methods, data, results, publications - all research activity)