Disclosure: Who, what, when, how, and why

ASU investigators have a compulsory responsibility to disclose financial interests and outside activities that reasonably appear to be related to the investigator’s research (including those of the investigator’s relatives).

Disclosure is required even if the investigator does not believe a conflict of interest exists.

ASU investigators must also confirm if they have no financial interests or outside activities to disclose.

Disclosure is easy and confidential, with a process crafted for simplicity while maintaining full compliance with ASU and sponsor policies.

Who needs to disclose?

• Principal Investigators (PI), Co-Principal Investigators (Co-PI), Investigators, Co-Investigators (Co-I), Senior/Key Persons
• Any ASU faculty, staff or researchers responsible for the design, conduct, or reporting research.
• Any individual with a financial interest or outside activity that could influence their research.

What needs to be disclosed?

1. Salary, remuneration, or other payments (≥ $1):
   • Consulting fees, paid appointments or positions, speaking engagements, honoraria, etc.
2. Equity or ownership interests ($0 threshold):
   • Equity or ownership interest in companies that reasonably appear to be related to the investigator’s research, including private companies and startups.
   • This disclosure requirement does not apply to passive investments (i.e. mutual funds or retirement accounts).
3. Sponsored or reimbursed travel ($0 threshold):
   • Travel paid for by an outside entity and given directly to the investigator, with no connection to a sponsored project at ASU.
   • This disclosure requirement does not apply to travel that is reimbursed or sponsored by a federal, state, or local government agency, or an institution of higher education.
4. Intellectual property rights and interests ($0):
   • Patents, copyrights or licenses generating income from research-related work.
   • Royalties, licensing income or patent-related payments.
   • This disclosure requirement does not apply to IP rights assigned to ASU and agreements to share in royalties related to such rights.
5. Official appointments ($0 threshold):
   • Board memberships or executive positions.
   • Relationships with entities sponsoring research.
   • Affiliate faculty positions.
6. Conflicts with procurement:
   • Financial ties to vendors or service providers connected to university purchases.
7. Other substantial interests.
8. Other financial interests.
   • Including venture or other capital financing.

When do investigators need to disclose?

• At proposal submission.
• Prior to engaging in any sponsored project.
• Within 30 days of acquiring a new financial interest/outside activity.
• Before a procurement event, especially if an investigator’s financial interest/outside activity is tied to a vendor or entity involved in research-related procurement.
• At least annually as required by ASU’s ongoing compliance process.

Note: Investigators with no financial interests or outside activities must provide a certification at proposal submission and time of award. 

How do investigators disclose?

• ASU’s ERA MyDisclosures Module.
• Investigators may be contacted by compliance coordinators if follow-up is needed.
• Click here to access a quick instructional video.

Why do investigators need to disclose?

• Required by ASU.
• Required by federal sponsors.
• Promotes objectivity in research and other sponsored project activities.
• Protects the design, conduct and reporting of externally funded projects from potential bias by an investigator’s conflicting financial interests.

Disclosure Process

Note:

• Ongoing transparency of financial interests and outside activities is mandatory for investigators at proposal submission and during the entire award lifecycle, regardless of COI determination.
• Research activities may not begin until a management plan has been fully implemented.
• ASU Research Compliance partners will manage sponsor notification activities if a COI management plan is implemented.

IPIRC committee

The Intellectual Property and Institutional Review Committee may also assist in the evaluation and disposition of faculty financial conflicts of interest. The committee is made up of faculty and staff representing the diversity of academic and research disciplines of the university. 

IPIRC meetings are currently held virtually typically every quarter, unless noted otherwise. Upcoming meetings are scheduled for:

Meeting dates for FY2025	Time
Monday, September 8, 2025	3:00 – 4:30 P.M.
Monday, November 24, 2025	3:00 – 4:30 P.M.
Monday, February 9, 2026	3:00 – 4:30 P.M.
Monday, April 13, 2026	3:00 – 4:30 P.M.