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Guide to Disclosure System

June 17, 2021

New! Researcher Disclosure System

The Disclosure of Financial Interests and Commitments System has been redone this year for researchers with significant changes to assist researchers in compliance with Federal sponsor disclosure and transparency requirements. Firefox and Chrome are both supported browsers; however, for best performance, it is recommended that you use Firefox. At this time, Safari is not supported.

The tabs below provide detailed instructions for the disclosure process.

Please also see the Disclosure System FAQs for answers to questions that we've received from faculty and researchers.

Starting a New Disclosure:

When you first log in, you will be presented with a button that says "Begin Disclosure." Because the system is entirely new this year, you will also see a button that says "Previously Disclosed Entities (2020)." Clicking this button will present you with a list of Entities you disclosed previously (2020). The hope is that this will serve as a starting point for this year's disclosures.

Welcome Page

Once you begin your disclosure you will see:

Page 1: Background, policy reminders and basic instructions for this new disclosure system.

What to expect in terms of disclosure: After clicking past Page 1, you will be asked a series of five (5) questions.

The first question, Question 1 is the "main" question. It will first ask you to consider all organizations, companies, universities or people (Entities) with whom you have a professional relationship or in which you have a financial interest:

screenshot of COI question 1

It will then ask you whether you have a commitment, financial interest or receive gifts from any of these Entities that meets one of the Detailed Criteria for Commitments, Financial Interests, or Gifts:

Detailed Criteria:

Commitments:

  • CONSULTING. Any entity or person that you have worked for as a paid or unpaid consultant.
  • ACADEMIC or RESEARCH APPOINTMENT. Any entity where you have an academic or research appointment (upaid or paid, honorary, adjunct, visiting or otherwise)
  • SCIENCE ADVISOR/RESEARCHER. Any foreign entity or person to which you have provided scientific advice or for which you performed research.
  • TALENT PROGRAM. Any government or group (entity) where you have participated in a foreign talent program. A Foreign Talent Program refers to programs which include any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.

Distinguishing features of a Foreign Government Talent Recruitment Program include:

  1. Monetary compensation provided by the foreign state to the targeted individual in exchange for the individual transferring their knowledge and expertise to the foreign country.
  2. Recruitment in this context refers to the foreign-state-sponsor's active engagement in attracting the targeted individual to join the foreign sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the U.S., or in the foreign state.
  3. Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at U.S. research facilities or receipt of federal research funds while concurrently receiving compensation from the foreign state.

Foreign Government Talent Recruitment Programs do not include:

  1. Research agreements between the University and a foreign entity.
  2. Agreements for the provision of goods or services by commercial vendors.
  3. Invitations to attend or present at conferences.
  • OTHER COMMITMENTS:
For Faculty: All entities when you have spent, on average, more than 13 days per academic quarter on activities for those entities outside of Caltech (excluding speaking at academic conferences or institutions or reviewing journal articles).For Research Staff and Postdocs: Any entity outside of Caltech where you have participated in any activity(ies) related to your Institutional Responsibilities.

Financial Interests:

For purposes of Financial Interests, "Institutional Responsibilities" means an Investigator's professional responsibilities on behalf of Caltech, and as defined by Caltech in its Conflicts of interest Policy and the Caltech Faculty Handbook. Institutional Responsibilities may include, for example, research, research consultation, teaching, professional practice, institutional committee or board memberships, service on review panels such as an Institutional Review Board or a Data and Safety Monitoring Board, and other administrative duties.

  • PERSONAL REMUNERATION/EQUITY. Any entity or person that paid you and/or provided you an equity/ownership interest (Financial Interest) that is related to your Institutional Responsibilities.
  • FAMILY MEMBER FINANCIAL INTEREST. Any entity in which you or an immediate family member (your spouse/domestic partner or dependent children) hold or have acquired any Financial Interests that are related to your Institutional Responsibilities.
  • PHS/NIH TRAVEL. If you have PHS (e.g. NIH) funding, any entity or person that reimbursed your travel, where the aggregate financial interest from that entity or person, including remuneration and travel is valued >$4999.00. You do not need to disclose reimbursed travel from any US federal, state or local governmental agency OR any US academic institution of higher education or its affiliated medical center in the US.

Gifts:

For purposes of Gifts, "Institutional Responsibilities" means an Investigator's professional responsibilities on behalf of Caltech, and as defined by Caltech in its Conflicts of interest Policy and the Caltech Faculty Handbook. Institutional Responsibilities may include, for example, research, research consultation, teaching, professional practice, institutional committee or board memberships, service on review panels such as an Institutional Review Board or a Data and Safety Monitoring Board, and other administrative duties.

  • Any entity or person that provided to you or your spouse/domestic partner or dependent child any Gift, including travel services or benefits from any person or entity related to your Institutional Responsibilities.

Once you have decided that you have an Entity that requires disclosure, choose "Yes." You will need to enter all Entities meeting any of these Detailed Criteria.

HINT: If you previously disclosed Entities, and your relationships are still active, you should disclose all of these. (See Previously Disclosed Entities list on your Disclosure Home Page)

screenshot of COI system - Previously Disclosed Entities

Choosing "Yes" to the initial Question 1 will open four (4) data entry fields:

  1. Name of Entity or Person
  2. Whether the Entity is Foreign, Domestic, Both, or Unknown. If you choose Foreign or Both, it will ask you for a country.
  3. A field to provide a URL for the Entity (Optional)
  4. And whether you have PHS/NIH Funding.
screenshot of "Add Entity"

Please provide these data and "Save."

The Entity will now appear on the LEFT MARGIN. When you are answering questions for that Entity, it will appear as BOLD and in ITALICS in LEFT MARGIN.

screenshot of "Add Entity"

You can then proceed to EITHER:

Answer Q1a about Commitments, Q1b about Financial Interests, and Q1c about Gifts OR

Add another entity and come back to Entity 1.

If you add another Entity, it will also appear in the LEFT MARGIN.

Add entity 2

NOTE: Both Entities have an "!" next to them, now. They are incomplete disclosures. Also, note that the middle of the page shows that you have 2 of 2 Entities that are NOT COMPLETE.

After you have entered all of your Entities, please make sure you COMPLETE them. You can navigate back by clicking on them from the LEFT MARGIN.

Completing the Disclosure:

Q1a Commitments

If any of these is true, you have a Commitment that requires disclosure. Choose "Yes" and choose all that apply:

Q1A Commitments - yes

After entering "Yes" to Q1a - Commitments and selecting all that apply, Q1b will appear:

Q1 b screenshot

If you answer "Yes," you will be prompted to answer a series of questions related to your financial interest and whether or not you have PHS/NIH funding. Answering the questions carefully will prompt you to disclose the information necessary pursuant to Caltech Policy and Federal Agency Sponsor requirements. FOR EXAMPLE:

Q1 b financial interests

continuation of q1b

continuation of q1b

continuation of q1b

When you are finished with Q1b, Financial Interest, you will be prompted to answer Q1c, Gifts.

Q1C

Again, if you answer "Yes," additional questions will be asked: For Example:

Q1C-2

Q1C-3

If appropriate, you will be asked if you have a Research Management Plan (Faculty) or an approved Outside Approval Request Form on file. Please attach (Research Management Plan) by uploading a current copy. Please associate your OA, if applicable.

NEW! You will be asked if you received anything that could be considered "Other Support" from this Entity. This information will be available to you in Question 4, later.

Other Support includes all resources (financial and in-kind) made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are used for research at Caltech or elsewhere.

Other Support NIH: https://grants.nih.gov/grants/forms/othersupport.htm

Current and Pending Support NSF: https://www.nsf.gov/pubs/policydocs/pappg20_1/pappg_2.jsp#IIC2h

Q1 Entity Other Support

SAVE! When Entity is COMPLETE, the "!" goes away and the "counter" shows only 1 of 2 Entities Incomplete:

Be sure to hit SAVE

Complete all Entities, before moving on to the Next Question. Make sure that all "!" are gone from the LEFT MARGIN. Note, you will receive "Error" Messages if your Disclosure for any Entity is incomplete. FOR EXAMPLE:

Error screen

You can also identify these "errors" by clicking on the "View Missing Fields" button.

When all entered Entities are complete, there are no further "!" in the LEFT MARGIN. You can advance to the Next Question. You will be prompted one last time to disclose any further Entities before moving to Q2. NOTE: You can add another Entity at ANY TIME by navigating back to Question 1 or by clicking the "Add Entity" button at the top. Please make sure all Entities are COMPLETE and you have added all Entities before "Certifying and Submitting." You won't be able to add Entities after submission until your Reviewer sees your Disclosure and either completes review or returns it to you.

Finished screen

Identify dual appointments and related funding, if any.

Q2

Identify whether or not you are an Institutional Leader. An Institutional Leader is the President, Vice President, Provost, Vice Provost, Division Chair or Center Director[FGC1] (the named Director of a recognized Caltech Center or Institute with an annual operating budget of $1M or more). This question will be further developed next year to help identify Institutional Conflicts of Interest.

Q3 Institutional Leader

This section extracts information from your disclosure and creates a report you can share with an administrator of your choice who can use the information for "Biosketch" or "Other/Current and Pending Support" disclosures to federal sponsors.

First, specify a delegate who can "see" this information. You do not need to specify someone if you do not wish to do so.

New! Biosketch

Next, review at your Biosketch information. Are there Entities missing? If yes, please add the other Entities:

Q4 biosketch

Finally, review your Other Support.

Remember Other Support includes all resources (financial and in-kind) made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are used for research at Caltech or elsewhere.

Other Support NIH: https://grants.nih.gov/grants/forms/othersupport.htm

Current and Pending Support NSF: https://www.nsf.gov/pubs/policydocs/pappg20_1/pappg_2.jsp#IIC2h

Other support

You can add Other Support that is not related to your outside activities/financial interests.

add other support

list of other support

Eventually, we hope to collect all of your Caltech grants, gifts, and support staff (postdoc/graduate student/visitor) funding here.

If you have PHS/NIH Funding, please make sure you disclose all relevant travel, not previously disclosed during the year by clicking the "Add Travel" button.

Q5 PHS Travel

If you do not have PHS/NIH Funding Select "No."

PHS funding - No

Once you have completed question 5, you will be prompted to certify your submission.

Please review all relevant Caltech Policies and have carefully read the certification. Ensure that you have added all the Entities you need to add (for now) and have answered all of the questions, Questions 1-5. Check the certification and "Submit."

certification

certification screen 2


Center Director

A Center Director is the named Director of a recognized Caltech Center or Institute with an annual operating budget of $1M or more.

Commitments

Any of the following, should be disclosed as Commitments:

  • CONSULTING. Any entity or person that you have worked for as a paid or unpaid consultant.
  • ACADEMIC or RESEARCH APPOINTMENT. Any entity where you have an academic or research appointment (upaid or paid, honorary, adjunct, visiting or otherwise)
  • SCIENCE ADVISOR/RESEARCHER. Any foreign entity or person to which you have provided scientific advice or for which you performed research.
  • FOREIGN TALENT PROGRAM. Any government or group (entity) where you have participated in a Foreign Talent Program.
  • OTHER COMMITMENTS:

For Faculty: All entities when you have spent, on average, more than 13 days per academic quarter on activities for those entities outside of Caltech (excluding speaking at academic conferences or institutions or reviewing journal articles).

For Research Staff and Postdocs: Any entity outside of Caltech where you have participated in any activity(ies) related to your Institutional Responsibilities.

Covered Equity Interest

A Covered Equity Interest is equity in a publicly traded entity where the value is >$4999. With regard to any non-publicly traded entity, any Equity is considered a Covered Equity Interest. A Covered Equity Interest does not include income from investment vehicles, such as mutual funds and retirement accounts, as long as the researcher does not directly control the investment decisions made in these vehicles.

Detailed Criteria

Detailed Criteria include Commitments, Financial Interests and Gifts related to your Institutional Responsibilities for Caltech.

Equity

Equity is limited to Covered Equity Interests which include equity (stock, stock options or other ownership interest) received from a publicly or non-publicly traded company.

Financial Interests

Financial Interests include all compensation >$4999 and Covered Equity Interests from all activities, including, but not limited to consulting, teaching engagements, seminars, lectures, and service on advisory committees or review panels.

Any of the following should be disclosed as Financial Interests:

  • PERSONAL REMUNERATION/EQUITY. Any entity or person that paid you and/or provided you an equity/ownership interest (Financial Interest) that is related to your Institutional Responsibilities.
  • FAMILY MEMBER FINANCIAL INTEREST. Any entity in which you or an immediate family member (your spouse/domestic partner or dependent children) hold or have acquired any Financial Interests that are related to your Institutional Responsibilities.
  • PHS/NIH FUNDING + EQUITY. Any entity in which you or an immediate family member hold any (regardless of value) equity in a non-publicly traded company must be disclosed if you have PHS/NIH Funding. If you have PHS/NIH funding founder's shares or equity of any value, even $0, must be disclosed as it is considered a Covered Equity Interest.
  • PHS/NIH TRAVEL. If you have PHS (e.g. NIH) funding, any entity or person that reimbursed your travel, where the aggregate financial interest from that entity or person, including remuneration and travel is valued >$4999.00. You do not need to disclose reimbursed travel from any US federal, state or local governmental agency OR any US academic institution of higher education or its affiliated medical center in the US.

Foreign Talent Program

A Foreign Talent Program refers to a program which include any foreign-state-sponsored attempt to acquire U.S. scientific-funded research or technology through foreign government-run or funded recruitment programs that target scientists, engineers, academics, researchers, and entrepreneurs of all nationalities working or educated in the United States.

Distinguishing features of a Foreign Government Talent Recruitment Program include:

  1. Monetary compensation provided by the foreign state to the targeted individual in exchange for the individual transferring their knowledge and expertise to the foreign country.
  2. Recruitment in this context refers to the foreign-state-sponsor's active engagement in attracting the targeted individual to join the foreign sponsored program and transfer their knowledge and expertise to the foreign state. The targeted individual may be employed and located in the U.S., or in the foreign state.
  3. Many, but not all, programs aim to incentivize the targeted individual to physically relocate to the foreign state. Of particular concern are those programs that allow for continued employment at U.S. research facilities or receipt of federal research funds while concurrently receiving compensation from the foreign state.

Foreign Government Talent Recruitment Programs do not include:

  1. Research agreements between the University and a foreign entity.
  2. Agreements for the provision of goods or services by commercial vendors.
  3. Invitations to attend or present at conferences.

Gifts

Gifts include any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, license, special access, equipment time, samples, research data, or other item having monetary value. A gift also includes services as well as gifts of training, transportation, local travel, lodging, meals, research hours, whether provided in-kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has occurred. For purposes of this disclosure, you do not need to disclose unsolicited gifts of textbook.

Disclose all Gifts received by you or your spouse/domestic partner or dependent child from any person or entity related to your Institutional Responsibilities.

Institutional Leader

An Institutional Leader includes the President, Vice President, Provost, Vice Provost Division Chair or Center Director. Transactions commonly handled by an Institutional Leader on behalf of Caltech include, but are not limited to:

  • Solicitation/negotiation for research funds or gifts
  • Negotiation of intellectual property
  • Procurement of goods or services
  • Negotiation for the use of Institute facilities

Institutional Responsibilities

Institutional Responsibilities means an Investigator's professional responsibilities on behalf of Caltech, and as defined by Caltech in its Conflicts of interest Policy and the Caltech Faculty Handbook. Institutional Responsibilities may include, for example, research, research consultation, teaching, professional practice, institutional committee or board memberships, service on review panels such as an Institutional Review Board or a Data and Safety Monitoring Board, and other administrative duties.

Investigator

An Investigator is the project director or principal investigator, co-investigators, and any other person, regardless of title or position, who is responsible for the design, conduct or reporting of the research funded by NSF or PHS, or proposed for such funding, which may include faculty, JPL staff, Caltech staff, post-doctoral scholars, students, external collaborators and co-investigators from other institutions or organizations.

Other Support

Other Support includes all resources (financial and in-kind) made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are used for research at Caltech or elsewhere.

Other Support NIH: https://grants.nih.gov/grants/forms/othersupport.htm

Current and Pending Support NSF: https://www.nsf.gov/pubs/policydocs/pappg20_1/pappg_2.jsp#IIC2h