Annual financial disclosures are a requirement for all federal grants and contracts. As of August 24, 2012, this policy applies to all federal agencies except those under the Public Health Service which have a separate policy.
In order to maintain the integrity of its federally funded projects, Empire State College has the responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by the personal financial interests of a faculty or staff member who is involved in the design, conduct, and/or reporting of a sponsored project and their immediate family members.
Research Foundation - As used in this policy, the term shall mean the Research Foundation of the State University of New York.
“Officer” and “employee” – Shall include any person representing or acting on behalf of the Research Foundation in any capacity in a sponsored program or project administered through the Research Foundation.
The Rule with Respect to Conflicts of Interest:
No officer or employee should have any interest, financial or otherwise, direct or indirect, or engage in any business or transaction or professional activity or incur any obligation of any nature, which is in substantial conflict with the proper discharge of his/her duties in the best interests of the Research Foundation.
No officer or employee should have any financial interest that will, or may be reasonably expected to, bias the design, conduct, or reporting of sponsored programs.
An Annual Disclosure of Financial Interests must be completed by project directors who receive federal funds. The Disclosure must be on file at the time the proposal is submitted and must be completed at least annually for as long as project remains active or sooner if there is a significant change in the project director’s financial interests. Annual disclosures must be completed by October 1.
The completed Annual Disclosure of Financial Interests must be submitted to the Director of Sponsored Programs for a preliminary review. All apparent conflicts of interest must be disclosed to the college’s President or designee for review and determination of whether a violation of this policy exists. Any determination by the college President or designee of a violation shall be forwarded to the President of the Research Foundation.
National Science Foundation – 2 CFR, Part 215, National Institutes of Health – 42 CFR, Part 50, Subpart F,
U.S. Department of Education – 34 CFR, Part 74.3
Financial Disclosure Form