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HomeConflict-of-Interest-and-CommitmentNewslettersApril Newsletter

April 2024: Disclosure of External Interests and Commitments Newsletter

This newsletter is intended to provide information to individuals who are required to maintain Disclosure Profiles under Stony Brook University’s Disclosure of External Interests and Commitments Policy (“Policy”). This issue will focus on what types of interests, activities, and relationships you are required to include in your Disclosure Profile. We will look at definitions, examples, and case studies, as well as address some Frequently Asked Questions (FAQs).

Policy Overview

What does the Policy require?

Stony Brook University’s Disclosure of External Interests and Commitments Policy (“Policy”) requires disclosers (as defined below) to maintain a Disclosure Profile, regardless of whether they have any external interests, activities, or relationships to report.

Who is required to have a Disclosure Profile?

The following individuals are required to maintain a Disclosure Profile:

  • Salaried faculty
  • Researchers (salaried and non-salaried)
  • Executive/senior leadership
  • Other personnel who advise on, negotiate or approve, on behalf of the University, transactions, arrangements or agreements with external parties involving the use of University resources.

See the Definitions section of the Policy for further information about these categories.

How is a Disclosure Profile maintained?

Disclosure Profiles are created and maintained in the myResearch Conflict of Interest module. Although managed by the Office of the Vice-President for Research, myResearch is the system of record for Disclosure Profiles under the Policy.   You are required to:

  • Certify the completeness and accuracy of your Disclosure Profile at least annually during the annual disclosure period (May 1st to May 31st).
  • Update your Disclosure Profile throughout the year by reporting changes within 30 days of their occurrence.



What interests, activities, and relationships need to be reported in a Disclosure Profile? 

Interests, Activities, and Relationships

All financial, personal, and professional interests, activities, and relationships that you or an immediate family member have with any non-University entity that creates, or could be perceived to create, a conflict of interest or commitment that:

  • Might be reasonably perceived to be related to your institutional responsibilities; or
  • May otherwise present a conflict of interest or conflict of commitment, or the perception of such a conflict, with your duties to the University.

What time period does this cover? 

Interests, activities, and/or relationships that:

  • Are current;
  • Occurred during the previous 12 months; and/or
  • Are anticipated in the future.

What is the monetary threshold that needs to be reported?

All interests, activities, and relationships that meet the criteria regardless of monetary amount (including no compensation) need to be reported.

What does “Immediate Family Member” mean?

  • Discloser’s spouse or domestic/civil union partner; and
  • Dependent children

What does “institutional responsibilities” mean?

An individual’s professional responsibilities on behalf of the University, including, but not limited to, activities such as research, research consultation, teaching, professional practice, and membership/service on University committees and panels (e.g.; Institutional Review Boards, Data and Safety Monitoring Board, accreditation committees, etc.).

What does “non-University entity” mean?

Non-University entities include but are not limited to companies, service providers, non-government organizations (NGOs), foundations, institutions of higher education, academic medical centers, research laboratories/centers/institutions, competitors, non-competitors, collaborators, foreign governments (which includes local, provincial, or equivalent governments), and any other for-profit or not-for-profit entities.

Are there any interests, activities, or relationships that are exempt from reporting in a Disclosure Profile?

The following exclusions apply and do not need to be disclosed:

  • Income from investment vehicles, such as mutual funds and retirement accounts, if you or an immediate family member does not directly control the investment decisions made in these vehicles.
  • Income from seminars, lectures or teaching engagements sponsored by a (United States) federal, state, or local government agency.
  • Income from service on advisory committees or review panels for a (United States) federal, state, or local government agency.

 

What are the reporting categories in a Disclosure Profile?

Interests, activities, and relationships that meet the criteria for reporting should be disclosed in one or more of the following categories.

Outside Employment

Any paid employment at a non-University entity (domestic or foreign). For clarification: this includes all affiliations or appointments that would constitute a Foreign Talent Recruitment Program.

Some examples:

  • Faculty appointments (regardless of title/rank/position).
  • Employment at external entities that rely on similar or the same expertise as your job responsibilities at Stony Brook University.

Caveat for outside employment for your spouse or domestic/civil union partner: You only need to disclose this employment when their employer does business with Stony Brook University and your spouse or domestic/civil union partner holds a position that makes significant business decisions on behalf of that employer.

Consulting/Other Professional Services

Any paid or unpaid consulting or professional services for a non-University entity. This includes paid and unpaid consulting and professional services whether domestic or with foreign entities or governments. Consulting and professional services are often based on a billable-hours basis.

Some examples:

  • Expert witness or other legal services
  • Project management
  • Creative services
  • Consulting that is conducted outside of your Stony Brook University job responsibilities.

External Resources and/or Support

Any resources or support (paid on your behalf or provided to you at no cost) that are provided to you by any non-University entity (foreign or domestic). This includes resources/support for your use at Stony Brook University locations as well as for use at non-Stony Brook University locations. It does not include resources or support that are administered by Stony Brook University, Stony Brook Foundation, or The Research Foundation for SUNY through a formal agreement.  

Some examples:

  • Laboratory/office space
  • Staff (including post-docs/students/visiting scholars)
  • Equipment or supplies
  • Materials
  • Animals
  • Gifts

Travel Support (Sponsored Travel)

Any travel expenses that are paid on your behalf or reimbursed directly to you by a non-University entity (domestic or foreign) that is related to your institutional responsibilities. This does not include travel that is paid for by funds managed by Stony Brook University, Stony Brook Foundation or the Research Foundation for SUNY.

Some examples:

  • Airfare reimbursed to you by the conference host for presenting at the event.
  • Hotel accommodation provided to you by the conference host for presenting at the event.
  • Airfare paid on your behalf by a potential research sponsor to attend a meeting.

Equity Relationships

Any equity held in a non-University entity (domestic or foreign) that is related to your institutional responsibilities.

Some examples:

  • Publicly traded stock, including options, warrants or promises.
  • Privately held stock or equity, including options, warrants, or promises.
  • Equity in a start-up company that has no value.

Note: When disclosing equity, the discloser can indicate either a percentage of ownership/stock or a dollar value. When reporting a dollar value, a discloser can optionally state a value of greater or less than $5,000.

Divestiture and Cash Pay-Out

Any equity in a non-University entity (domestic or foreign) that was included in a Disclosure Profile and then subsequently sold. If only a portion was sold, then the change should be reflected in both the equity and divestiture/cash pay-out categories.

Editorial Services

Any editorial services provided to a non-University entity (domestic or foreign) that is related to your institutional responsibilities.

Some examples:

  • Journal Editor, Managing Editor, Assistant Editor
  • Scientific Editor
  • Academic Editor
  • Royalties received from publication activities (e.g.; manuscripts, books, films, music)

Board Service

Any position on a Board of Directors or Board of Trustees (and other similar types of boards) for a non-University entity (foreign or domestic) that is related to your institutional responsibilities.

Some examples:

  • Governing Board
  • Advisory Board
  • Board of Directors
  • Managing or Executive Board
  • Fundraising Board

Honoraria and Prizes

Any honoraria or prizes from a non-University entity (domestic or foreign) that is related to your institutional responsibilities. Honoraria are distinct from employment and consulting arrangements, where the latter usually implies a contractual relationship. Honoraria are most often one-time payments.

Some examples:

  • Guest speaker
  • Guest lecturer
  • Participation in a conference, seminar, meeting or similar type of event
  • Writing or publishing an article
  • Prizes (Nobel Prize, Honorary Degrees, etc.)

Intellectual Property Rights and Interests

Any payments or promises of payment from a non-University entity (domestic or foreign) that has licensed (or has options to license) any intellectual property rights either directly or through any other entity (including the State University of New York and the Research Foundation for SUNY), where such intellectual property was developed by the discloser.   

Some examples:

  • The University has licensed technology to a non-University entity where the discloser is an inventor.
  • A non-University entity has licensed technology from a previous institution/company where the discloser is an inventor.
  • A non-University entity has an option to license technology from the University.

Other Appointments

Any external paid or unpaid positions/obligations at a non-University entity (domestic or foreign) that are related to your institutional responsibilities that do not fit into any of the above categories.  For clarification: This would include any type of appointment, whether paid or unpaid, that is related (or could be perceived to be related) to your institutional responsibilities.

Some examples:

  • Faculty appointments
  • Visiting/volunteer/guest/honorary titles/appointments
  • Officer, director, advisor titles

CASE STUDIES

Case Study # 1: External Resources or Support

Professor Jay is a faculty member in the Biochemistry and Cell Biology department and is planning to receive mice from UC Berkeley and the University of Amsterdam for a research project. UC Berkeley sent a Material Transfer Agreement (MTA) for the transfer of the mice, but the University of Amsterdam did not send an MTA.

Question: Does Professor Jay need to disclose mice received from these institutions?
Answer: Professor Jay would need to disclose the mice received from an external party (domestic or foreign), if there was no formal agreement between the institution and the Research Foundation for SUNY. Therefore, Professor Jay would disclose the mice received from the University of Amsterdam but would not disclose the mice received from UC Berkeley.

Case Study # 2: Immediate Family Member

Professor Considine is a faculty member in the Microbiology and Immunology department that researches various biomarkers for arthritis. Dr. Considine’s spouse (Immediate Family Member) works at Amgen with salary and stock options. Dr. Considine’s spouse is involved in bench research developing cutting edge products for the treatment of rheumatoid arthritis.

Question: Does Professor Considine need to report the spouse’s employment and/or stock options at Amgen?

Answer: Professor Considine does not need to report the spouse’s employment at Amgen because the spouse is not in a position that makes significant business decisions at Amgen. Professor Considine does need to report the spouse’s stock at Amgen, as this can reasonably be related to Dr. Considine’s institutional responsibilities at the University.

Case Study # 3: Sponsored Travel

Professor Samuel is a faculty member in the History department and has been invited to speak at the International Conference on Politics and History. The conference organizers are paying for the hotel room and are reimbursing the airfare costs. Professor Samuel will need to rent a car, which the conference organizers will not pay for or reimburse. The presentation is based on Professor Samuel’s University research.

Question: Does Professor Samuel need to report the hotel room, airfare and/or car rental?

Answer: The conference is related to ProfessorSamuel’s institutional responsibilities therefore the next step is to determine which costs should be considered sponsored travel and reported. The reimbursement of the airfare and payment for the hotel room would constitute sponsored travel as they are being paid for on Professor Samuel’s behalf. The car rental is not reportable because Professor Samuel is paying for that expense.

Case Study #4: Equity

Professor Michaels is a faculty member in the Civil Engineering department and has a diverse stock portfolio. The stock portfolio (that is not part of a mutual fund or retirement account managed by a third party) includes shares in Disney, Inc., Proctor & Gamble Company, Comcast, Caterpillar, and Brookfield Infrastructure. Professor Michaels teaches advanced civil engineering courses and conducts research in the field of construction and design.

Question: Does Professor Michealsneed to report all these stocks?

Answer:  Professor Michaels needs to report his holdings in Caterpillar and Brookfield Infrastructure, as these relate to Professor Michaels' institutional responsibilities. The shares in Disney, Inc., Proctor & Gamble, and Comcast do not need to be reported as these are not related to Professor Michaels' institutional responsibilities.

 Frequently Asked Questions (FAQs)

Does outside employment need to be disclosed?

It depends on if you are currently working for an external company or organization that might be reasonably perceived to be related to your institutional responsibilities.

For example: You are a faculty member in the Computer Science Department with a focus on Internet security and you also work for Google part time, helping them develop security protocols to protect consumer privacy. You should report your Google employment, might be reasonably perceived to be related to your institutional responsibilities.

Does an immediate family member’s interest(s) need to be disclosed?

It depends on if the immediate family member has interests, or they have arelationship (financial, personal, or professional), with a non-University entity that could be perceived to be related to the discloser’s institutional responsibilities.                                                                                                                                                 

Examples that would require disclosure:

  • Your immediate family member works for a startup company that licenses technology from the University that is in the same research field as you.
  • Your immediate family member owns a business that creates and sells materials to the University.

Examples that would not require disclosure:

  • Your immediate family member has stock options in a multimedia company that is not related to your institutional responsibilities.
  • Your immediate family member, a student at the University, has a paid summer internship at IBM, and you are a faculty member in the Sociology department.

If animals or research materials are received for free, does this need to be disclosed?

It depends on if the animals or research materials are received with or without a formal agreement through the University. If there is no formal agreement then the receipt of the mice would be required to disclose in the External Resources or Support category. Remember that a Material Transfer Agreement can be used when research materials are transferred into or out of the University.

Do other academic appointments need to be disclosed?

All academic appointments whether domestic or foreign are required to be disclosed.   Remember that other academic appointments should follow the Provost’s Guidelines for Approval of Appointments at Other Institutions.

Do all equity interests need to be disclosed?

Only those equity interests (both in publicly traded or privately held companies) that are related to your institutional responsibilities are required to be disclosed. Remember that disclosure is required for privately held companies when (1) there is no perceived value for the company and (2) the company is related to your institutional responsibilities.

 What details of sponsored travel need to be reported?

When reporting sponsored travel, the following details about the trip should be disclosed:

  • Name of the non-University entity providing support
  • Total dollar value (if not known, then an estimate)
  • Dates of travel
  • Purpose of travel.

For more FAQs, please go to the University and Sponsor Disclosure website.

For questions and/or assistance, contact Marina Galanakis, COI Coordinator at marina.galanakis@stonybrook.edu or Susan Gasparo, Director for Research Security at susan.gasparo@stonybrook.edu.