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FAQ's for External Interest Disclosure Form Instructions
The revised Web–based Disclosure Form, which was developed with significant input from our faculty, is designed to offer a more efficient means for faculty and other research personnel to meet their obligations to disclose outside activities and financial interests. The disclosure form also incorporates the mandatory training on PHS COI regulations and Yale COI policy. You will need your Yale NetID and password to login to the Web–based Disclosure Form.
For Yale (Non-PHS, Non-NSF):
If you have royalties resulting from intellectual property, you will be asked to report them on the intellectual property page. If you receive royalties related to intellectual property, please answer in the affirmative that you do have a license agreement and you will be asked to provide further details in the intellectual property page.
For PHS & PHS-like Sponsors:
Under the PHS regulations certain royalties are subject to disclosure, as are other interests related to intellectual property. Royalties from and agreements to share in royalties related to intellectual property rights paid to you (or to your spouse or dependent children) are covered by the regulation and are subject to the $5,000 threshold for a significant financial interest.
Royalties you receive directly from Yale are excluded from the PHS definition of a Significant Financial Interest if you are currently employed or otherwise appointed by Yale. Unlicensed intellectual property that does not generate income is also excluded from the PHS definition of Significant Financial Interest. Accordingly, Yale does not treat these particular interests in and of themselves as “significant.” However, depending upon certain circumstances, Yale may take intellectual property rights into consideration as a factor in determining whether or not a financial conflict of interest exists. Also, because Yale’s Institutional Review Board (IRB) may consider intellectual property rights in its review of human research protocols and for purposes related to the protection of research participants, you should include these intellectual property interests on the Disclosure form when prompted by the appropriate question.
For NSF:
If you have royalties resulting from intellectual property, you will be asked to report them on the intellectual property page. If you receive royalties related to intellectual property, please answer in the affirmative that you do have a license agreement and you will be asked to provide further details in the intellectual property page.
For PHS & NSF:
Under the PHS regulations certain royalties are subject to disclosure, as are other interests related to intellectual property. Royalties from and agreements to share in royalties related to intellectual property rights paid to you (or to your spouse or dependent children) are covered by the regulation and are subject to the $5,000 threshold for a significant financial interest.
Royalties you receive directly from Yale are excluded from the PHS definition of a Significant Financial Interest if you are currently employed or otherwise appointed by Yale. Unlicensed intellectual property that does not generate income is also excluded from the PHS definition of Significant Financial Interest. Accordingly, Yale does not treat these particular interests in and of themselves as “significant.” However, depending upon certain circumstances, Yale may take intellectual property rights into consideration as a factor in determining whether or not a financial conflict of interest exists. Also, because Yale’s Institutional Review Board (IRB) may consider intellectual property rights in its review of human research protocols and for purposes related to the protection of research participants, you should include these intellectual property interests on the Disclosure form when prompted by the appropriate question.
Please provide additional details about the relationship with the entity. Specific details might include the length of the relationship, contractual obligations, the level of involvement, and the compensation structure.
Certain senior, non–faculty administrators designated by the President are also required to submit annual disclosures of outside activities and financial interests. These disclosures must be prepared on the Conflict of Interest Disclosure Form for Senior Administrators and submitted to the Office of the Vice President and General Counsel. The form will be provided to those administrators who are designated to submit them.