What to Disclose

As part of its commitment to promoting objectivity in research and in compliance with federal regulations, the University at Albany requires all investigators who apply for, receive, plan to participate in, or are participating in external funding administered through the Research Foundation for SUNY (e.g., grants, contracts, cooperative agreements, etc.) to submit a Certification of Disclosure.

The intent of this process is to remove bias or the perception of bias from the research process by identifying and managing any conflicts of interest due to an investigator’s external commitments or financial interests, both foreign and domestic. This Disclosure Statement must be filed annually and should be updated within 30 days of when your foreign or domestic significant financial interests, significant obligations or sponsored travel change. It requires full disclosure of all foreign and domestic Significant Obligations, Significant Financial Interests and Sponsored Travel. Questions concerning the Investigator Conflict of Interest Process or this Disclosure Statement may be addressed to the Conflict of Interest Administrator, at [email protected].

The following question relates to any outside entities, foreign and domestic, with which you or an immediate family (spouse and dependent children) have relationships outside of this institution. Outside entities include foreign and domestic companies, service providers, non-government organizations (NGOs), foundations, and any other for-profit or not-for-profit entities (hereinafter called "companies") with which you or an immediate family member had a relationship in the previous 12 months, or with which you or an immediate family member anticipate a relationship within this calendar year. 

Payments or Remuneration - The following is a non-exclusive list of payments that you must disclose: 

  • Payments from all foreign and domestic non-institutional sources, whether or not you received an IRS Form 1099, W-2, or K-1, except as noted in the Exclusions below.
  • Any payment or promise of payment of any kind to you or an immediate family member, either in currency or in-kind, for any purpose, whether or not you believe the purpose or the payment is related to your employment at this institution, except as noted in Exclusions, below.
  • Payments or promises of payment from a foreign or domestic company that has licensed or has options to license any intellectual property (patents, inventions, copyrights, trademarks) either directly or through any other foreign and domestic entity, where such intellectual property was developed by you or an immediate family member.
  • Any payments made to a company on your behalf. For example, you are part of an organized consulting group that receives payment for your work, that consulting group and the companies that paid you through the consulting group are to be disclosed.
  • Payments from any corporate foreign or domestic sponsor that pass through an intermediary should be attributed to the corporate sponsor. For example, a pharmaceutical company hires a public relations firm to arrange seminars in support of the pharmaceutical company's product. You or an immediate family member speak at a seminar and receive compensation. The payments should be attributed to the pharmaceutical company regardless of which company's name appears on the check you receive or anticipate receiving).

Equity holdings or ownership - You are required to disclose any shares of stock you or an immediate family member own, including options, warrants, or promises of such, etc., whether the company is privately or publicly held or is foreign or domestic. The following is a non-exclusive list of ownership or equity holdings that you must disclose:

  • Pharmaceutical, biotechnology, medical device, or other companies related to research conducted on the campus.
  • Start-up companies
  • Companies that provide any tangible items to this institution, including equipment, office, medical or computer supplies, furniture, etc., regardless of cost.
  • Companies that provide services or other intangibles to this institution, including but not limited to medical services, housekeeping, laundry, landscaping, information technology, consulting, accounting, etc., regardless of cost.

Significant Obligations – You are required to disclose any positions such as officer, trustee, director, consultant, advisor, adjunct professor that you or an immediate family member hold from a foreign or domestic entity outside the University at Albany.

Exclusions - The following exclusions apply to payments or ownership to you or an immediate family member. These excluded items need not be disclosed: 

  • Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles;
  • Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency, a (United States) Institution of higher education as defined at 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; or
  • Income from service on advisory committees or review panels for a federal, state or local government agency, a (United States) Institution of higher education as defined at 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.

All Sponsored Travel, including foreign and domestic travel must be disclosed unless it is funded through the University. The following information must be disclosed:

  • Purpose:
  • Dates (start/end or start/duration):
  • Sponsor/Organizer:
  • Destination:
  • Monetary value and any additional information about the travel:

Additional Information and Guidance