All WCM faculty members and staff are required to complete the Disclosure of Conflicts Survey.
The Disclosure of Conflicts Survey is required at a minimum once annually; however, should any financial interests change over the course of the year, an update to the Disclosure of Conflicts Survey is required within 30 days of the change.
For those who have no interests to disclose, the submission of the Disclosure of Conflicts Survey is required as a certification of such.
If you have financial interests to disclose you will be required to answer the initial questions plus an additional set of questions for each entity with which you have a financial interest. For example, if you have financial interests in three different entities, you will be required to answer the additional set of questions for each of those entities.
If you are an investigator on research that is overseen by the Food & Drug administration (FDA):
You will also need to report financial conflicts to the research sponsor for their reporting, as required, to the FDA. Further information on conflicts reporting in FDA-Sponsored Research.
Please refer to the Policies and Forms page for specific definitions on what constitutes a financial interest and/or commitment that may be a conflict to the institution.
External Consulting Agreements
Travel disclosures can be made through your conflicts survey in Weill Research Gateway.
Travel for a U.S. Non-Profit Entity
Reimbursed travel expenses and other compensation greater than $5,000 per year in aggregate from a single U.S. non-profit entity need to be reported.
You only must report travel sponsored or reimbursed by a single U.S. non-profit entity if:
- The trip was more than $5,000,
- Multiple trips for that entity in aggregate exceed $5,000,
- You receive more than $5,000 for services from that entity, or
- A combination of trips and services in aggregate from a single entity exceeds $5,000.
You do not have to report travel reimbursed or paid for by Cornell University, nor travel paid by:
- a federal, state, or local government agency,
- a U.S. non-profit institution of higher education as defined at 20 U.S.C. 1001(a),
- a U.S. academic teaching hospital, U.S. medical center, or
- a research institute that is affiliated with an institution of higher education.
There are additional rules for individuals applying for or funded by Public Health Services (PHS), which includes the National Institutes of Health (NIH) and other non-profit agencies that chose to invoke PHS COI policy.
Sponsored travel means (a) travel expenses paid to an investigator or travel paid on an Investigator's behalf, by a single entity in any 12 month period and/or (b) travel reimbursed to or paid on behalf of an Investigator's spouse and dependent children by a single entity in any 12 month period.
Travel for a For-Profit Entity
All paid or reimbursed travel paid or reimbursed by "for-profit" entities must be disclosed within 30 days of completing travel.