Disclosure System Frequently Asked Questions
Updated June 16, 2021
Following are questions that have been received regarding the new Disclosure of Financial Interests and Commitments System. If you do not see your question answered below, please contact us at [email protected].
FAQs
- How do I submit a Caltech Financial Interest and Commitment Disclosure?
ANSWER: Log in to the Access.Caltech web page: http://access.caltech.edu (Please note that a Virtual Private Network (VPN) connection is required for off-campus access.)
Enter your Username and Password (this is the same as your IMSS/Kronos login credentials) and click the OK button.
Select "Disclosure of Financial Interests and Commitments" under Administrative Services, and complete the form. - I am having technical difficulties with the system. What should I do?
ANSWER: First, please make sure you are using either Firefox (preferred browser) or Google Chrome. Unfortunately, at this time, Safari is not supported. If your technical problem is not related to your browser, please contact IMSS at 626-395-3500. - I am a Professor Emeritus. I no longer have research funding, conduct research or perform academic services for Caltech. Do I need to complete a Financial Interest and Commitment Disclosure?
ANSWER: No. As long as you are not conducting research or teaching for Caltech, you do not have to complete a disclosure. Please contact your Division DOO and have them request an exemption on your behalf. - I am a Visiting Scientist, Visitor, Guest, Visiting scholar or postdoc, or Occasional Employee. I am working in a research lab. Do I need to complete a Financial Interest and Commitment Disclosure?
ANSWER: Yes. Anyone conducting research, in any capacity, should complete a disclosure. - I am an External Affiliate at campus. I am working in a research lab. Do I need to complete a Financial Interest and Commitment Disclosure?
ANSWER: Maybe. It depends upon your agreement with Caltech, whether or not your home institution has a federally compliant COI policy, and the funding in the research lab at Caltech you will be working in. Please check with the Office of Research Compliance if you are unsure ([email protected]). - I am a campus employee and have an appointment at JPL. Do I need to disclose at JPL as well as on campus, using the Financial Interest and Commitment Disclosure?
ANSWER: No. You should only complete one disclosure, either at campus or at JPL. If your primary appointment is at campus, please complete the campus disclosure. If your primary appointment is at JPL, complete the JPL disclosure. - I forgot to complete my answer to Question 2. I haven't yet certified and submitted my answer. Can I go back to Question 2?
ANSWER: You can navigate from question to question using the "Question X" buttons across the top, as long as you have not submitted your disclosure.
8. I assume previously disclosed entities will appear when one has to update the forms every year or more frequently? Will the app require refilling these in from a list or provide the user with a list that auto-fills for Question 1?
ANSWER: This year (2021), previous disclosures will not repopulate. A list of your previously disclosed entities is available on your Disclosure "Home Page" (see picture).
9. How far back to I need to report Commitments, Financial Interests or Gifts?
ANSWER: The disclosure period is for 1 year prior. You should disclose all commitments, financial interests or gifts received since June 1, 2020. You need not disclose any of these things that happened prior to June 1, 2020 as these should have been reported during last year's disclosure cycle. If you did not disclose something during last year's disclosure cycle that should have been disclosed, please contact the Office of Research Compliance ([email protected]) for guidance.
10. How do I tell whether or not my disclosure for an Entity is complete or not?
ANSWER: The Entities appear on the left side-margin as you add them. If they are incomplete they show with a "!" in a circle. When complete, the "!" disappears.
- What commitments should I disclose?
ANSWER: By answering the questions presented to you after entering a particular entity, you will be prompted to disclose the commitment you are required to disclose. Generally, any of the following, should be disclosed as commitments:
- CONSULTING. Any entity or person that you have worked for as a paid or unpaid consultant.
- ACADEMIC or RESEARCH APPOINTMENT. Any entity where you have an academic or research appointment (upaid or paid, honorary, adjunct, visiting or otherwise)
- SCIENCE ADVISOR/RESEARCHER. Any foreign entity or person to which you have provided scientific advice or for which you performed research.
- FOREIGN TALENT PROGRAM. Any government or group (entity) where you have participated in a Foreign Talent Program.
- OTHER COMMITMENTS:
- For Faculty: All entities when you have spent, on average, more than 13 days per academic quarter on activities for those entities outside of Caltech (excluding speaking at academic conferences or institutions or reviewing journal articles).
- For Research Staff and Postdocs: Any entity outside of Caltech where you have participated in any activity(ies) related to your Institutional Responsibilities.
- I am a Visiting Associate. Do I need to disclose my home institution as a commitment, or is it understood that I have this commitment?
ANSWER: All visitors (Visitors, Visiting Associates, Visiting Professors, or Guests) performing or collaborating on research while at Caltech should disclose their affiliation with their home institution (if one exists). It is unlikely that this will be determined to be a conflict of commitment or interest, but disclosure is required.
- The question concerns the "Commitments" subsection of the "Detailed Criteria" section and, specifically, the commitment to: "Any foreign entity or person to which you have provided scientific advice or for which you performed research."
Should research collaborators outside Caltech, both junior and senior (students, postdocs and faculty), be included in this disclosure? Please note that reporting every single instance of such cases would be rather time-consuming, and perhaps even impossible.
ANSWER: (1) Performing Research: You must provide the names of entities or persons for which you performed any research, whether or not you were reimbursed for that research. (2) Providing Scientific Advice: You should provide the names of entities or persons with whom you have had significant scientific interaction or exchange that also required a "commitment" of your time in the past year. Participation on a national science advisory board for any country must be included in your disclosure. General conversation at a conference or a one time phone or zoom conversation is not significant. Conversations and exchanges leading to a publication are likely to be significant and require time commitment. For some general guidance around collaboration, please see: Collaborative Relationships & Foreign Components: When to Report to NIH.
- Do I need to disclose service on NSF proposal review panels?
ANSWER: Generally, you do not need to disclose time spent on NSF (US Government) proposal review panels as this is considered part of your normal academic activities. However, if you spend more than 13 days per quarter on this type of review activity, even if it is for the US Government, you should discuss the activity with your Division Chair. If you have a permanent appointment/position at NSF (e.g. you are on detail, serve on the NSB, or the like) or you spend any time on a foreign government proposal review panel, you must disclose this.
15. What financial interests should I disclose?
ANSWER: By answering the questions presented to you after entering a particular entity, you will be prompted to disclose the financial interests you are required to disclose. Financial Interests include all compensation >$4999 and Covered Equity Interests from all activities, including, but not limited to consulting, teaching engagements, seminars, lectures, and service on advisory committees or review panels. Generally, any of the following, should be disclosed as financial interest:
- PERSONAL REMUNERATION/EQUITY. Any entity or person that paid you and/or provided you an equity/ownership interest (Financial Interest) that is related to your Institutional Responsibilities.
- FAMILY MEMBER FINANCIAL INTEREST. Any entity in which you or an immediate family member (your spouse/domestic partner or dependent children) hold or have acquired any Financial Interests that are related to your Institutional Responsibilities.
- PHS/NIH FUNDING + EQUITY. Any entity in which you or an immediate family member hold any (regardless of value) equity in a non-publicly traded company must be disclosed if you have PHS/NIH Funding. If you have PHS/NIH funding founder's shares or equity of any value, even $0, must be disclosed as it is considered a Covered Equity Interest.
- PHS/NIH TRAVEL. If you have PHS (e.g. NIH) funding, any entity or person that reimbursed your travel, where the aggregate financial interest from that entity or person, including remuneration and travel is valued >$4999.00. You do not need to disclose reimbursed travel from any US federal, state or local governmental agency OR any US academic institution of higher education or its affiliated medical center in the US.
16. Do I need to disclose my NSF, NIH, or other Federal Agency awards?
ANSWER: You do not need to disclose any awards, contracts or gifts that are made to Caltech in your personal financial interest disclosure. If you have received, personally, any funds from awards, consulting fees, contracts or gifts that are used for research, you must disclose these.
17. I am a paid consultant or visiting scholar for Company A and my lab receives funds from Company A in either the form of sponsored research or via a gift to Caltech that sponsors my postdoc. Do I need to report my consulting or scholar activity?
ANSWER: Yes, include Company A as an entity in your disclosure. Make sure you disclose that Company A sponsors your research or directly or indirectly sponsors lab personnel, and that your relationship with Company A is related to your Institute Responsibilities and research funding.
18. I have $5000 worth of stock in Company A. My lab receives funds from Company A in either the form of sponsored research or via a gift to Caltech that sponsors my postdoc. Do I need to report my investment interest?
ANSWER: Yes, include Company A as an entity in your disclosure. As you have direct control over your investment in Company A and Company A sponsors your research or directly or indirectly sponsors lab personnel (through a gift), and this investment is related to your Institute Responsibilities and research funding, you will be prompted to disclose these relationships.
19. I have $5000 worth of stock in Company A. I believe Company A might sponsor research at Caltech, but I do not receive any of these funds. Do I need to report this investment?
ANSWER: Maybe. Include Company A as an entity in your disclosure. Based upon your answers, the system may prompt you to disclose information regarding Company A. Because you have direct control over your investment in Company A, and may be responsible for some aspect of Caltech's relationship with Company A, such as licensed technology from your lab, or negotiating an agreement with Company A for research sponsorship at Caltech, this would be related to your Institute Responsibilities and should be disclosed. If in doubt, err on the side of caution and disclose or call for help.
20. I have $500,000 worth of stock in my retirement fund. I do not control the individual investments, but I know that part of my portfolio includes stock in Company A. My lab receives funds from Company A in either the form of sponsored research or via a gift to Caltech that sponsors my postdoc. Do I need to report my consulting investment interest?
ANSWER: No. You do not have direct control over your investment in Company A. This is not a Covered Equity Interest. However, if you have other relationships, commitments or gifts from Company A, you can enter it as an Entity into the system to confirm that there is no required disclosure.
Questions Coming Soon.
Questions Coming Soon.
Questions Coming Soon.
- I am Caltech Faculty and have an appointment at JPL. Do I need to disclose at JPL as well as on campus, using the Financial Interest and Commitment Disclosure?
ANSWER: No. You should only complete one disclosure, either at campus or at JPL. If your primary appointment is at campus, please complete the campus disclosure. If your primary appointment is at JPL, complete the JPL disclosure. If you have a dual appointment, though, you should answer this question 2, YES. You will then be prompted to provide your title at JPL and how your salary is covered.
- What is the question about "Institutional Leader" about?
ANSWER: This question is to identify whether or not you are an Institutional Leader. An Institutional Leader is the President, Vice President, Provost, Vice Provost, Division Chair or Center Director (the named Director of a recognized Caltech Center or Institute with an annual operating budget of $1M or more). This question will be further developed next year to help identify Institutional Conflicts of Interest.
- What is this question about?
ANSWER: This question extracts information from your disclosure and creates a report you can share with an administrator of your choice who can use the information for "Biosketch" or "Other/Current and Pending Support" disclosures to federal sponsors. - Who should I delegate?
ANSWER: Someone who can access the information shown in Question 4. The plan is to have this page available outside of the disclosure system, so it can be used for to help complete Federal Agency disclosure requirements for Biosketch and Other/Current and Pending Support, as necessary. - What are the start and end dates for their access to the information?
ANSWER: This is the timeframe the individual will have access. It is probably a good idea to grant access for a year and re-authorize next year.
Questions Coming Soon.
- I submitted my disclosure and then realized that I forgot to enter an Entity. What should I do?
ANSWER: Once submitted, the disclosure needs to be reviewed by the pre-reviewer/reviewer or returned by them to the discloser. This keeps the workflow moving correctly. This is why there are several reminders to make sure you have added all your entities before submitting.