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Definitions

Company/Business Entity

A sole proprietorship, partnership, association, joint venture, corporation, firm, trust, foundation, or other organization or entity used in carrying on a trade or business, including parent organizations of such entities or any other arrangement in which an entity operates through a subsidiary.

Compensation

Anything of economic value, however designated, which is paid, loaned, granted, given, donated, or transferred to any person or business entity for or in consideration of personal services, materials, property, or the like.

Disclosure of External Professional Activities (DEPA)

The form used by University of Colorado Boulder employees, students and other persons of interests (POIs) to report information regarding significant financial and personal interests outside of the university that might present conflicts of interest or commitment.

Discloser

A person who is required to submit a conflict of interest and commitment disclosure in the form of the DEPA. Refers to all faculty, and any other employee, or student, consultant, collaborator, or any other person acting as an agent of, or affiliated by contract or agreement with the university who has responsibility for the design, conduct or reporting of research. (See Research Personnel for an expanded list detailing to whom this disclosure policy applies).

Employee

Any person who is employed by the University, whether full or part time, and includes but is not limited to staff, faculty, postdoctoral appointees, residents and students.

Equity Interests

Stocks, stock options, other ownership interests (or entitlements to the same) in non-publicly traded (privately held) and publicly traded, financially interested companies.

Family

Family means, for the purposes of this policy, any family member with whom you have a close relationship.  Family members include, but are not limited to: spouse, parents (yours and spouse's), child, sibling, son/daughter-in-law, step relatives, domestic partner, relatives of domestic partner in any relationship stated above. 

Income

The amount of money or its equivalent received during a period of time in exchange for labor or service, from the sale of goods or property, or as profit from financial investments (e.g., salary, consulting fees, honoraria, royalties, and dividends).

Intellectual Property

Any ideas, inventions, technology, creative expression and embodiments thereof, in which a proprietary interest may be claimed, including but not limited to patents, copyrights, trademarks, know-how, biological materials, and other forms of intellectual property legally recognized now or in the future.

Investigator/Principal Investigator/Principal Director

Traditionally limited to the principal investigator and co-principal investigators; some federal regulations include this to mean any research personnel or other key personnel, regardless of title or position at a university, who is responsible for the design, conduct, or reporting of research, proposed research, or educational activities.

Key Personnel

An individual involved in research and who is supported in salary, supplies, space or other resources by grant funding. 

Payments for Services

May include but is not limited to consulting fees, honoraria, gifts, entitlements, other types of "in-kind” compensation.

PHS

Means Public Health Services agencies, including NIH. An expanded list of agencies can be found at the following website: http://www.hhs.gov/about/orgchart/.

POI

An acronym for "Person of Interest." In order to access the DEPA reporting system, individuals who are not university employees must be established in the payroll system as POIs. POI status may also be necessary to access the conflict of interest educational training modules.

Research

A systematic investigation designed to develop or contribute to generalizable knowledge. The term encompasses basic and applied research and product development.

Research Personnel

  • An individual who is essential to the research process regardless of title or position; includes all tenure track faculty (all levels), research professors (all levels), adjunct faculty, visiting faculty, museum associates, librarians, and any other research employees (professional research associates [PRAs], research associates). Also includes students (graduate and undergraduate) with responsibility for the design, conduct or reporting of research. Note: adjoint faculty, lectures and teaching assistants, Professional Exempt (P.E.s) are NOT necessarily considered essential to research processes and are not universally required to submit annual conflict of interests and commitment disclosures. Non-university employees such as collaborators, consultants and subcontractors may be allowed to submit a disclosure or certify disclosure from another institution, depending upon funding agency requirements.
  • Research Committee Members (i.e., IRB members, IACUC members and/or other research review committees).
  • Staff who negotiate or execute research agreements on behalf of UCB Area/Program Administrators, Staff of Grants and Contracts and staff of theTechnology Transfer Office.

Significant Financial Interest (SFI)

Includes anything of monetary value received from an entity outside the university that meets or exceeds established thresholds. Examples include, but are not limited to, salary or other payments for services from a third party/financially interested company; dividends, equity interest; intellectual property rights (and royalties from such rights)(See incomepayments for servicesequity interests, etc.). Thresholds are set in accordance with current funding agency regulations:

  • 1.   For Non-PHS/NIH-funded research personnel, who are NOT recipients of funding from Public Health Services [PHS] agencies, the threshold values are:
    • $10,000 for the AGGREGATED SUM of income and equity interest
    • 5% ownership interest in any single entity.
  • 2.   For PHS/NIH-funded, key personnel, who are recipients of funding from Public Health Services [PHS] agencies including but not limited to NIH, the threshold values are:
    • $5,000, alone, in income/payments for service
    • $5,000 for the AGGREGATED SUM of income and equity interest received/ownership of a publicly traded company;
    • ANY equity interest received/ownership of non-publicly traded company.
  • 3.   For PHS/NIH-funded key personnel, travel reimbursement or sponsored travel related to institutional responsibilities in ANY amount must be report as SFI. The COIC Office/Committee will determine if a conflict exists based on current federal regulations. Exclusions from this requirement include travel that is reimbursed or sponsored by the University of Coloradoa federal, state, or local government agency; another institution of higher education; an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.

Note: While SFI literally denotes a financial interest, personal/family gain other than strictly financial is also considered in reviewing potential conflicts of interest.

The term Significant Financial Interest does NOT include:

  • Salary or other payments for services from the University of Colorado;
  • Income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
  • Income from service on advisory committees or review panels for federal, state of local government agencies, institutions of higher education as defined by 20 U.S.C. 1001(a), an academic teaching hospital, medical center, or research institution of higher education;
  • Equity interests that, when aggregated for the investigator and the investigator’s spouse and dependent children, do not exceed, or are not expected to exceed, the previously stated thresholds, during a twelve-month period.
  • Salary, royalties or other payments from a single entity, that, when aggregated for the investigator and the investigator’s spouse and dependent children,do not exceed, or are not expected to exceed, the previously stated thresholds, during a twelve-month period.
  • Income from/ownership in mutual funds and/or pension/retirement funds, as long as the discloser does not directly control the investment decisions made in these entities;
  • Any ownership interests in a business entity by an investigator on a Phase I SBIR grant or application with that business entity.
  • (In regard to the requirement for PHS/NIH-funded key personnel) travel: travel that is reimbursed or sponsored by the University of Colorado; a federal, state, or local government agency; another institution of higher education; an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.

Small Business Innovation Research Program (SBIR)

The extramural research program for small businesses that is established by the Awarding Components of certain Federal agencies under Pub. L. 97-219, the Small Business Innovation Development Act, as amended. For the purposes of this policy, the term SBIR includes the Small Business Technology Transfer (STTR) Program, which was established by Pub. L. 102-564. (Definition adapted from section 510 of the National Science Foundation’s Grant Policy Manual).

Technology Transfer Office (TTO)

A university department that “pursues, protects, packages and licenses to business the intellectual property generated from research at CU. The TTO provides assistance to faculty, staff and students, as well as to businesses looking to license or invest in CU technology.”

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