Disclosures of Financial Interests & Outside Activities

Required Disclosures

As relationships between Portland State researchers and community partners continue to grow, it is important for PSU to maintain high research integrity standards. Therefore, any potential for conflict of interest or conflict of commitment -- where an individual's financial or personal considerations may affect or appear to affect their PSU activities related to externally sponsored programs -- must be disclosed, reviewed, and managed in accordance with state and federal regulations and PSU policy.

PSU investigators and project directors proposing and/or working on sponsored projects are obligated to disclose signficant financial interests and outside activities to University officials so that potential conflicts of interest or commitment can be evaluated and managed.

Disclosures are required at the time of proposal submission and/or receipt of awards from external sponsors. Disclosures must be updated within 30 days of the addition of new financial interests or outside activities and confirmed on at least an annual basis.

Sponsored Projects Disclosure of Financial Interest and Outside Activities Policy

Disclosure submission is prompted by PSU's electronic research administration system, Kuali Research. Principal Investigators and Co-Investigators of sponsored projects will receive an email notification with a link to complete or update the Disclosure Form. (The vendor-recommended browser for Kuali Research is Google Chrome.)

PSU Subrecipients Relying on PSU Policy Use this link to submit a disclosure: Subrecipient FCOI Disclosure Form

Disclosing Outside Interests & Activities

When preparing the disclosure form, individuals should include the following items:

  • Payments for services (consulting, lectures, advisory board payments, or honoraria)

  • Equity interests, i.e. stocks, stock options, and other ownership interests

  • Intellectual property rights (e.g., licenses and royalties)

  • Donations (monetary, unrestricted funds, in-kind designated for research)

  • Relationships and activities with foreign institutions and funding agencies

  • All external professional activities

Individuals are not required to disclose the following:

  • Salary or other payments from PSU

  • Ownership of shares in a mutual fund

  • Book Royalties

See Guidance for Disclosing Outside Activities & Other Commitments for examples of actvities to disclose.

Disclosure Procedures

  • Investigators are prompted to disclose/update certain financial interests and outside activities at time of sponsored project proposal submission or award receipt (and update disclosure within 30 days of a change to financial interests).

  • Disclosures are reviewed to see if they meet specific criteria outlined in sponsor regulations to be considered "significant" financial interests.

Potential Conflicts of Interest or Commitment

Interests and activities with real or apparent ability to directly and significantly affect either the design, conduct or reporting of funded research, or the performance of duties and responsibilities on behalf of Portland State University may be considered in conflict with those of the professional responsibilities of the PSU employee.

Conflicts of Commitment occur when an individual's commitment to external activities adversely affect their capacity to meet University responsibilities.

Financial Conflicts of Interest exist in any situation in which an individual has an outside interest that might affect, or appear to affect, their judgment in carrying out University responsibilities.

A financial conflict of interest may exist in educational, purchasing and research settings. Examples of potential conflicts include, but are not limited to, the following:

  • Using University resources in activities that may lead to financial gain for the faculty member (or their immediate family).

  • Payments from outside entities or stock interests greater than $5,000.

  • Using University resources to benefit an external entity.

  • Using the name of the University in promoting activities that may lead to financial gain for the faculty member (or their immediate family).

  • Interacting with students in external as well as internal roles, e.g. employing students for non-University work.

  • Engaging in research in which a faculty member (or their immediate family) has a financial interest, including interests in a start-up company and/or interests related to licensed intellectual property.

  • Having a relationship or affiliation between the faculty and the source of information or materials.

  • Competing with the University for clients, contracts, etc.

  • Financial involvement of a faculty member (or their immediate family) with an outside organization, or holding a position in an outside organization.

  • Having an external interest that could be implicated in internal University decisions, e.g., contracts, hiring, research, or in giving advice.