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Guide to Disclosure of Financial Interests and Commitments System


Researcher Disclosure System

The Disclosure System was revamped in 2021, for researchers, with significant changes, to assist researchers in compliance with Federal sponsor disclosure and transparency requirements. Firefox, Chrome, and Safari are all supported browsers; however, for best performance, it is recommended that you use Chrome.

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 log in your landing page will look something like this:

DFIC Disclosure Help Manual 2023-1_Welcome1

IF YOU HAVE ALREADY SUBMITTED YOUR DISCLOSURE AND YOU NEED TO MODIFY/UPDATE/ADD TO IT:

If you have already submitted your disclosure, it is still in review, and it needs to be updated, your landing page will look like this:

DFIC Disclosure Help Manual 2023-1_Welcome2

Please contact your Division Operations Officer and request that your disclosure be returned to you. When it is returned, you will see the "Resume Disclosure" button and be able to modify it accordingly.

Starting a New Disclosure:

When you first log in, you will be presented with a button that says, "New Disclosure" or "Resume Disclosure." Choose "New Disclosure" to start a brand-new disclosure or "Resume Disclosure" to complete one that you began earlier and that is in draft.

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OR

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Once you begin your disclosure you will see:

Page 1a: Background, policy reminders for your "Annual Disclosure of Financial Interests and Commitments."

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Page 1b: Instructions for Annual Disclosure of Financial Interests and Commitments Form.

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This Annual Disclosure of Financial Interest and Commitments Form will ask you to disclose your commitments/relationships and financial interests with individuals or companies outside of Caltech (Entities). You will also be asked some status questions (JPL appointment/PHS/NIH or DOE funding/Institutional Leadership). There are a total of five (5) Questions/Sections to complete, but you may have more than one Entity to disclose in Question 1, and, if you have PHS/NIH, DOE, or NSF funding, you may have to complete travel disclosures for the year in Question 5. You are asked to answer all the Questions to the best of your knowledge and to certify the completeness and accuracy of your disclosure and that you have read and understood relevant Caltech policies.

You are required to complete the annual disclosure process by July 31, 2023.

The information you submit is considered confidential and will only be used to evaluate potential conflicts. The information will not be shared outside of Caltech unless required by law, regulation or contract.

An employee is credited with completion when all the questions are answered and the disclosure is submitted. Confirmation of completion will be provided. Completed disclosures will be securely stored online so that you may verify that your disclosure is accurate and current.

If you have any technical questions on Campus, please contact IMSS at 626-395-3500, at JPL please call 818-354-7054. For substantive questions, please contact either your Division Chair, the Office of Research Compliance or Human Resources at Campus or the Ethics Office at JPL.

What to expect in terms of disclosure: After clicking "Next" on 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:

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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:

Please consider the different types of COMMITMENTS, FINANCIAL INTERESTS, and GIFTS. If you have one or more of these commitments to, financial interests in/from, or gifts from any Entity or person, you must disclose that Entity.

Commitments:

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  • CONSULTING. Any entity or person that you have worked for as a paid or unpaid consultant.
  • BOARD SERVICE: Any entity on which you serve as a board member, including scientific advisory boards.
  • ACADEMIC or RESEARCH APPOINTMENT. Any entity where you have an academic or research appointment (unpaid 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. A foreign government-sponsored talent recruitment program is any effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. For further information see: /international_collaboration/foreign-talent-recruitment-programs
  • 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:

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For purposes of Financial Interests, "Institutional Responsibilities" means a researcher's professional responsibilities at Caltech, and as defined by Caltech in its Conflicts of interest Policy and the Caltech Faculty Handbook. Institutional Responsibilities 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.

Examples of interests "related to" one's Institutional Responsibilities: I'm paid to consult on widgets, my lab researches widgets; entity sells sensors, my lab designs novel sensors; I own equity in Company X, Company X sells equipment to my Division; I teach/lecture at Caltech, and I teach/lecture at entity; I use the computing resources of the entity to perform research. If you use a product, resources or service of an entity in your research, teaching or administrative services, and you have a financial interest in that entity, the interest is related to your Institutional Responsibilities. If you are consulting or advising in your area of scientific expertise for the entity, and you have a financial interest in that entity, the interest is related to your Institutional Responsibilities.

  • 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.
  • FOUNDER. Any entity in which you are a founder.
  • INCOME FROM INTELLECTUAL PROPERTY. Any Entity from which you received income or equity as a result of your intellectual property rights and interests (e.g., royalties or licensing revenue from patents, copyrights). This does not include royalties received from Caltech.
  • INVESTMENT. Any entity or person who provided venture or other capital investment in a company where you are a founder.
  • REIMBURSED TRAVEL. PHS/NIH or DOE: If you have PHS (e.g., NIH) or DOE 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 academic teaching hospital, medical center or research institution in the US. If you receive NHS funding, you should disclose any reimbursed travel where the aggregate financial interest including the travel is valued >$4999.00. You do not have to disclose reimbursed travel from a US federal, state or local governmental agency or any not-for-profit institutions in the US.

Gifts:

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For purposes of Gifts, "Institutional Responsibilities" means a researcher's professional responsibilities at Caltech and as defined by Caltech in its Conflicts of Interest Policy and the Caltech Faculty Handbook. Institutional Responsibilities 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.

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HINT: If you previously disclosed Entities, your previously disclosed Entities will show on the Left Side. If your entities are listed on the left, you may simply click on the Entity, review and confirm that the previously disclosed information is correct. If you no longer have an interest in or a commitment to the previously disclosed Entity, you can Delete the Entity. It will show under "Deleted Entities" going forward.

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Choosing "Yes" to the initial Question 1 will open five (5) data entry fields:

  1. Name of Entity
  2. Name of Contact or Collaborator (Person)
  3. Whether the Entity is Foreign, Domestic, Both, or Unknown. If you choose Foreign or Both, it will ask you for a country. Type in the name of the country and select the magnifying glass to find the country name in the list. Select the appropriate country.
  4. A field to provide a URL for the Entity (Optional)
  5. And whether you have PHS/NIH or DOE Funding.

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.

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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.

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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:

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A Consultant is one who engages in Consulting Activities as described in Caltech's Faculty Handbook, Chapter 7.

A foreign government-sponsored talent recruitment program is any effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position). Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation. For further information see: /international_collaboration/foreign-talent-recruitment-programs

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

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Q1b will now appear:

  • In the past year (12 months), were you, (including your spouse, domestic partner or dependent child) paid by this entity? (Payments include all remuneration, and can include salaries, consulting fees, royalties and honoraria.)
  • In the past year (12 months), have you, (including your spouse, domestic partner or dependent child) received or held any equity/ownership interest in this entity?
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If you answer yes to one or both of these questions, you will be prompted with a series of additional questions, related to your financial interest and whether or not you have PHS/NIH or DOE funding. Answering the questions carefully will prompt you to disclose the information necessary pursuant to Caltech Policy and Federal Agency Sponsor requirements. FOR EXAMPLE:

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  • Related to your Institutional Responsibilities.

This is a KEY question. It is essential that you answer this question correctly.

Answer this question, interpreting everything you do for Caltech in the broadest sense. If in doubt, call the Office of Research Compliance, email caltechcoi@caltech.edu, or say "yes."

Is the activity or product (physical or service) of the entity broadly related to your field of research, teaching activity, or administrative responsibility at Caltech?

  • If you use the entity's product, resource, or service in your research, you must answer YES.
  • If you are consulting or advising in your area of scientific expertise for the entity, you must answer YES.

(Examples of "related": I'm paid to consult on widgets, my lab researches widgets; entity sells sensors, my lab designs novel sensors; I own equity in Company X, Company X sells equipment to my Division); I teach/lecture at Caltech, and I teach/lecture at entity; I use the computing resources of the entity to perform research)

  • Threshold value of Financial Interest.

Your Financial Interest is considered significant if it is $5000 or more or if you hold 5% or more of an entity's equity. For equity in non-publicly traded entities, it is often difficult to assign a monetary value. If you are a founder in such a company, answer this question "Yes."

  • Equity Questions

Is all or some portion of your interest in equity or ownership?

Is this equity or ownership interest in a publicly traded company?

Equity in non-publicly traded companies is considered a significant financial interest.

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  • US Government/Domestic Academic Institutions

Is this Entity a US federal, state or local governmental agency OR is it a US academic institution of higher education or its affiliated medical center in the US?

Is your ENTIRE financial interest in/from this Entity an honorarium received from seminars, lectures, teaching or service on a US Government advisory or review panel or for a US academic institution of higher education or its affiliated medical center in the US?

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  • Financial Interest Type and Value

Check the Interest, indicate who in your family holds the interest and the approximate value. For non-publicly traded equity, you may select "Value not Determined."

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  • Cumulative Value
Provide the sum of all financial interests received in the last 12 months (include reimbursed travel from the entity, if any).
  • Job, Position or Appointment Title
  • Amount of time committed to this entity in HOURS per WEEK.
  • Relationship between your Financial Interests and your Institutional Responsibilities

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  • Relationships between your financial interests and Sponsored Research.
Do you have any current or potential sponsors of your research, where the sponsored research (grant, contract, research agreement, etc.) could be perceived as related to or overlapping with your Financial Interest(s) or activity with this Entity?

For example, the entity makes widgets and I have a DOE award to understand how widgets work.

  • Select all sponsors where there may be relationship or overlap.
Please select each Sponsor where the sponsored research may be perceived to be related to or overlapping with your Financial Interest(s) from or activity with this Entity?
  • For any Sponsor selected, is there perceived or actual overlap between your disclosed Financial Interest(s) or related activity(ies) and the subject matter or scope of work for your grant or sponsored research project?
  • Describe, in detail, for EACH sponsor, the perceived or actual overlap between your financial interest(s) or activities with the Entity and your sponsored research project.

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TRAVEL as a Financial Interest

  • Reimbursed or Sponsored Travel from the Entity
  • US Government or Domestic Academic Institution/Hospital
  • Aggregate cost of Reimbursed Travel >$2000
  • Disclosure/Association of Travel with this Entity
Did you disclose this entity reimbursed/sponsored travel in the Caltech Travel Disclosure System?If no, please select the "Link" to disclose this Travel and Associate it with this entity disclosure:

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A pop-up window will open. It will show your travel disclosed in the last 12 months. In the future, you will be able to select/associate previously disclosed travel (Not Associated) with this entity. However, this year we cannot do this. To add the new (undisclosed) travel, select the "Add New Travel" button on the right.

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A new window will pop up and you will be asked a few questions to determine whether or not travel constitutes a financial interest or not and needs to be disclosed:

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  • The Entity Information pre-populates.
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  • Enter destination(s) and dates. The revised system allows you to include multiple stops during the same trip.
  • Enter Value (Estimates are OK) of Travel
  • Select Purpose of Trip and Describe if further description is necessary (e.g., you have personal travel interspersed with business travel)
  • Describe the relationship between your Institutional Responsibilities and the travel.
  • When you select "Save" a new entry appears on your list of travel:

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  • If you select "View Associated Travel" on the main DFIC page, you will see the Entity Trip, a pop-up will display with all travel associated with the entity.
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Don't forget to include the trip value in your overall financial interest for the year…

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

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

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It is important that you include any gift given to benefit you, or your immediate family members.

It is important that you include any gift given to benefit you, or your immediate family members.

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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.

Research Management Plan (Professorial Faculty)

Faculty, you will be asked if you have a Research Management Plan on file:

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If you answer "No," a Research Management Plan may be needed if there is an actual or potential conflict of interest or commitment. Your Pre-Reviewer, Reviewer or someone from the Office of Research Compliance will contact you.

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If you answer "Yes," please ATTACH your current or most recent Research Management Plan and include its expiration date. (Unless otherwise indicated, the RMP expires one year after the Division Chair's or Final Reviewer's Signature.

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The RMP Attachment will now show:

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Outside Activity Form (Research Staff and Postdocs)

Per PM-9, all staff and postdocs are required to complete an Outside Activity Request Form (OA), PRIOR to beginning any outside activity. You are required to disclose such an activity or any financial interest received from that activity within 30 days of starting the activity or acquiring a financial interest (e.g., pay, equity, etc.) from that activity. The DFIC allows you to associate your OA with the disclosure:

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If Yes, Associate your OA Form:

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Select the Entity (e.g., Entity1):

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Select "OK" to associate the entity:

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If No, Create a New Form:

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Complete ALL sections of the form required. PLEASE make sure your answers in the OA application are consistent with your answers in your disclosure. Pay particular attention to the hours/week and any overlap or relationship between your outside activity and your work for Caltech.

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The last Section of the form includes Management Plan Requirements. That is, these are conditions and things you MUST or MUST NOT do in order to be able to engage in the outside activity. These things manage any conflicts of interest or commitment you may have:

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Once you have created the OA, Associate it with your DFIC:

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You will receive an email:

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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/NIH-Disclosures-Table.pdf

Current and Pending Support NSF: https://www.nsf.gov/bfa/dias/policy/disclosures_table/jan2023.pdf

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SAVE! SAVE OFTEN!!

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

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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:

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

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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.

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Identify dual appointments at JPL and Campus and related funding, if any.

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Identify whether or not you are an Institutional Leader. An Institutional Leader is the President, Vice Provost, Division Chair or Center Director (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.

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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.

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

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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/NIH-Disclosures-Table.pdf

Current and Pending Support NSF: https://www.nsf.gov/bfa/dias/policy/disclosures_table/jan2023.pdf

The first section will display "Possible Other Support" from Entities that you disclosed. The next section will allow you to add Possible Other Support from other entities not associated with Entities disclosed in your DFIC (i.e., you have no financial interest or commitment).

HINT: Focus on completing the DFIC and complete your disclosure. Manage your other support using the Biosketch and Other Support Application (BSOS) or have your Delegate do this for you.

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

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If you have PHS/NIH OR DOE Funding, please make sure you disclose all relevant travel, not previously disclosed during the year. In the system, you can disclose all travel associated with disclosed Entities. If you have travel not associated with any Entity, you may disclose it through the travel system found on Access.caltech.edu.

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

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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."

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Once your disclosure is "under review" you will not be able to edit it. If you need to make a change, please contact your Division Operations Officer or the Office of Research Compliance (caltechcoi@caltech.edu) to return your disclosure to you so you can make changes before it is reviewed.


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.
  • BOARD SERVICE. Any entity on which you serve as a board member, including scientific advisory boards.
  • ACADEMIC or RESEARCH APPOINTMENT. Any entity where you have an academic or research appointment (unpaid 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.
  • FOUNDER. Any entity in which you are a founder.
  • INCOME FROM INTELLECTUAL PROPERTY. Any Entity from which you received income or equity as a result of your intellectual property rights and interests (e.g., royalties or licensing revenue from patents, copyrights). This does not include royalties received from Caltech.
  • INVESTMENT. Any entity or person who provided venture or other capital investment in a company where you are a founder.
  • REIMBURSED TRAVEL.
    • PHS/NIH or DOE: If you have PHS (e.g., NIH) or DOE 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 academic teaching hospital, medical center or research institution in the US.
    • If you receive NHS funding, you should disclose any reimbursed travel where the aggregate financial interest including the travel is valued >$4999.00. You do not have to disclose reimbursed travel from a US federal, state or local governmental agency or any not-for-profit institutions in the US.

Foreign Talent Program (Foreign Government Sponsored Talent Recruitment Program)

A Foreign Government-sponsored Talent Recruitment Program (FGTRP) is any effort organized, managed, or funded by a foreign government, or a foreign government instrumentality or entity, to recruit science and technology professionals or students (regardless of citizenship or national origin, or whether having a full-time or part-time position).

  • Some foreign government-sponsored talent recruitment programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government.
  • Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of Federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities.
  • Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.

For further information see: /international_collaboration/foreign-talent-recruitment-programs

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/NIH-Disclosures-Table.pdf

Current and Pending Support NSF: https://www.nsf.gov/bfa/dias/policy/disclosures_table/jan2023.pdf

While the DFIC helps to collect information from your personal disclosure that should be in your Biosketch and Other/Current and Pending Support documentation, it is not comprehensive. Your grant manager can see this information in the Biosketch and Other Support (BSOS) IF you have granted them access!

Please see the Biosketch and Other Support Manual to help with the BSOS Application.

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