Disclosing Outside Activities & Financial Interests
Federal, state and UT System regulations require the disclosure of individual financial interests and the management and reporting of significant financial interests that create a conflict of interest related to their UT Health San Antonio duties and responsibilities or research performed at UT Health San Antonio.
Who must disclose their outside professional activities and significant financial interests?
Faculty, staff or trainees responsible for the design, conduct or reporting of research, regardless of appointment type.
When must disclosures of outside activities or financial interest be made?
- Within the first thirty days of employment (new employees)
- When there is overlap with the outside activity or interest and your UT Health SA responsibilities
- Before accepting outside employment or compensation
- Before serving on the board of a for-profit entity
- Annually (when notified), usually the beginning of the calendar year
Where do I disclose my outside activities and financial interests?
What is ERMS-COI?
ERMS-COI is the online system used by Faculty and Exempt Staff to report external (or outside) activities. Each reported activity is referred to as a “disclosure”. ERMS-COI provides a single portal to capture information used to fulfill several administrative and reporting needs such as:
- Conflicts of Interest
- Conflicts of Commitment
- Activities that require prior approval (such as outside employment)
- Activities that must be reported annually to UT System and the NIH
What is a Significant Financial Interest?
A “Significant Financial Interest” is defined by the PHS regulations as anything of monetary value and includes, but is not limited to:
- salary or other payments for services (e.g. consulting fees or honoraria)
- equity interests (e.g., stocks, stock options or other ownership interests)
- intellectual property rights (e.g., patents, copyrights, and royalties from such rights)
The definition applies when:
- Salaries, royalties, paid authorship, or other payments for services (including travel reimbursements) if, when aggregated for the individual and family, are expected to equal or exceed $5,000 from any single source for any 12-month period.
- Equity interest including stock, stock options, or other ownership interest or entitlement to such interest, valued by reference to public prices or other reasonable measures of fair market value, if, when aggregated for the individual and family, equals or exceeds $5,000 in value as determined by reference to public prices or other reasonable measures of fair market value.
- For the purposes of research involving human research participants, any amount as defined above must be included in the Conflict of Interest Report (Form X) to the IRB as part of the IRB protocol submission.
What is a research conflict of interest?
COI refers to situations where the individual has the opportunity to influence UT Health San Antonio’s business, administrative, academic, research, clinical, or other decisions in ways that could lead to personal financial gain or advantage or could appear to cause bias in the design, conduct, or reporting of research or educational activities.