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  • Disclosure of Significant Financial Interest

    For Public Health Service (PHS, including NIH) and National Science Foundation (NSF) Grants and Cooperative Agreements, including Malign Foreign Talent Recruitment Program (MFTRP) compliance
  • Please read Smith College’s Policy on Academic Financial Conflict of Interest in Research for Public Health Service and National Science Foundation Grants and Cooperative Agreements. The following disclosure is made pursuant to the requirements of the regulation, Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought (42 CFR Part 50 and 45 CFR Part 94), and the requirements set forth by the National Science Foundation. This disclosure must be completed prior to the submission of a grant application, updated annually, and whenever new reportable significant financial interests are acquired.

  • Definitions

  • Significant financial interests that could directly affect the design, conduct, or reporting of research must be disclosed. Smith College will review disclosures to determine if financial interests may create an actual or potential financial conflict of interest with the project and the institutional responsibilities of the investigator(s Federal regulations require that financial conflicts of interest are appropriately reported and managed.

    Significant Financial Interest is defined as one or more of the following that reasonably appears to be related to the investigator’s institutional responsibilities: (a) any equity interest (e.g., stock, stock option, or other ownership interest) in a non-publicly traded entity, or the value of remuneration (e.g., salary, consulting fees, honoraria, paid authorship) received from the entity which, when aggregated, exceeds $5,000; (b) equity interest or the value of remuneration from a publicly traded entity which, when aggregated, exceeds $5,000; (c) intellectual property rights and interests, upon receipt of income related to such rights and interests which, when aggregated, exceeds $5,000; and (d) any reimbursed or sponsored travel (i.e., paid on behalf of the investigator. The disclosure period is the twelve months preceding the date of disclosure.

    The term does not include (a) salary, royalties or other remuneration from Smith College, including intellectual property rights assigned to the college and agreements to share in royalties related to such rights; (b) income from seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by a federal, state, or local government agency, a U.S. institution of higher education, a teaching hospital, medical center, or research center affiliated with an institution of higher education; or (c) income from investment vehicles, such as mutual funds or retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles. These financial interests are not included in the definition regardless of total dollar amount (the threshold amount is not applicable due to the source of funding

    Investigator is defined as the Principal Investigator and any other person responsible for the design, conduct, or reporting of research, educational, or service activities funded, or proposed for funding. For the purposes of this disclosure requirement, the term "investigator" includes the investigator's spouse and dependent children.

  • DISCLOSURES

    (Skip this section if no disclosures)
  • Malign Foreign Talent Recruitment Program Definition

    A foreign talent recruitment program is any program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.
  • Malign Foreign Talent Recruitment Program Compliance

    By signing this page, you are certifying that, in accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. 19232), you have been made aware of and have complied with your responsibility under that section to certify that you are not a party to a malign foreign talent recruitment program.
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