Transparency & Disclosure
- Be thorough and complete in accounting for all forms of research support, including funding from foreign sources and gifts in support of the research, in the NIH’s other support, the NSF’s current and pending and similar documentation submitted to other sponsors.
- Disclose financial interests in AIR, the University’s Activities, Interests and Relationships Management System , at the time of proposal submission through the Office of Sponsored Research (OSR), the School of Medicine Sponsored Programs Office (SPO), or the Office of Human Research Ethics (OHRE) or within 30 days of acquiring new interests as required in the Policy on Individual Conflicts of Interest and Commitment. Activities requiring disclosure include domestic and foreign consulting relationships, financial interests, investment or board positions in a start-up company regardless of location, etc. The Conflict of Interest Program (firstname.lastname@example.org) can provide additional guidance on what you need to disclose and how and when to make a disclosure.
- You need to be aware of your reporting obligations regarding outside professional activities, called External Professional Activities for Pay (EPAP), through the AIR Management System. All faculty and EHRA non-faculty employees are required to receive approval in advance of engaging in external activities for pay, in accordance with the Policy on External Professional Activities of Faculty and Other Professional Staff. Additional information can be obtained from your Department Chair and/or HR Representative.
- Discuss any invitation for any academic appointment or position at another domestic or international institution (visiting, honorary, or other) with your Dean’s Office prior to accepting the appointment, as required by the UNC – Chapel Hill Faculty Handbook.
- Disclose with your Dean’s Office involvement in any foreign recruitment or “talent” programs. These programs are of particular interest to the federal government, due to the potential risk of undermining U.S. economic and security interests.
- NIH has now released updated guidance via Notice number NOT-OD-19-114 and an associated FAQ. As a result, you must now disclose much more information than you’ve had to disclose in the past.