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Disclosure Thresholds

Disclosure Thresholds

In addition to the OU Board of Regents Conflict of Interest Policy, OUHSC researcher are also required to address federal regulations. The PHS FCOI Policy applies to many federal sponsors and requires disclosure of Significant Financial interests on an annual basis and when a new relationship or activity arises.  When completing your annual COI disclosure, please be sure to address the requirements below.

Significant Financial Interests (SFIs) are defined as:

Nature of SFI Threshold Excluded (Do Not Disclose)
Compensation and/or other payments for service Exceeds $5,000, when aggregated Annual Cumulative Compensation received is less than $5,000, as well as any compensation received for lectures, seminars, teaching engagements, or service on advisory committees or review panels relating to federal, state, or local government agencies, an institution of higher education as defined in 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, and compensation received from OUHSC funds
Equity interests in a publicly-traded entity Exceeds $5,000 when aggregated Interests in any single entity valued at less than 5% as well as interests in any entity through personal retirement accounts and mutual funds
Equity interests in a non-publicly-traded entity 0 / Any Interests in any entity through personal retirement accounts and mutual funds
Intellectual property rights and interests upon receipt of income related to such rights and interests Exceeds $5,000 Royalties received from OUHSC funds, and unlicensed intellectual property that does not generate income
Sponsored or reimbursed travel Exceeds $5,000 Travel administered through OUHSC funds, and travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined in 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.

*Note that while these are the definitions required by regulations and the OUHSC Board of Regents policy, the sponsor, your unit, or your department may require more stringent disclosure thresholds.