Faculty Disclosure FAQs
1. Why did the disclosure process change?
New Department of Health and Human Service (HHS) regulations governing financial conflicts of interest (COI) in sponsored research went into effect August 24, 2012. The University of Miami responded to these new regulations by changing its COI disclosure process in several ways.
The new regulations place a bigger burden on institutions that receive federal funding for sponsored activities to monitor and manage their financial COIs. This required the University to upgrade its systems and processes to comply with the regulations.
2. Who needs to disclose Outside Professional Activities (OPAs)?
All full-time faculty, University of Miami Medical Group members, and Miller School faculty members who could provide clinical or teaching services for UHealth must disclose their OPAs to UM by the end of each calendar year.
In addition, all UM community members who could be involved in sponsored activities are required to disclose their OPAs and financial/obligatory interests (FOIs) related to Institutional Responsibilities (IRs), prior to submission of a proposal/contract on which they will be team members, or at least annually, using the Disclosure Profile System (DPS). Further, if currently funded by the Department of Health and Human Service (HHS), all Investigators must complete travel disclosures that related to the IRs.
3. I did not engage in any outside professional activities. Do I need to disclose?
4. Do faculty members still need to complete their Faculty Disclosure Form (FDF)?
No. The new Disclosure Profile System (DPS) replaces the FDF. Full-time faculty, University of Miami Medical Group members, and Miller School faculty members who could provide clinical or teaching services for UHealth, must disclose their outside professional activities (OPAs) to UM in the DPS by the end of each calendar year.
You can update your disclosure profile any time it is necessary throughout the year; any information you enter is saved and will be available for editing until data collection for the next year begins. However, if you receive funding for sponsored activities or are paid by sponsored accounts, you are required to enter your disclosures in the DPS within 30 days (rather than waiting until you are compensated for them). Even if you do not receive funding for sponsored activities or receive payments from sponsored accounts, we strongly recommend that you enter your disclosures within 30 days. We also recommend that you use the DPS as your mechanism for recording and tracking your OPAs.
In accordance with the new HHS regulations, faculty members involved in sponsored activities will also be required to complete the Financial and Obligatory Interest (FOI) section of the DPS, in addition to the OPA section. FOIs that must be disclosed are those related to your IRs.
PHS funded Investigators must also disclose the occurrence of any reimbursed travel or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their IRs.
This disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency, an Institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
5. What happens if OPAs are not entered in a timely fashion?
6. Where is the disclosure data stored? Who has access to it?
7. Do voluntary or part time faculty members need to complete the DPS?
8. How does the DPS derive its answers for the questionnaire?
9. Are there entities/payors that are excluded from the UM disclosure requirements?
10. Does UM regard performance of OPAs as somehow improper?
11. What if I have multiple OPAs with the same entity?
Your disclosure profile is capturing your relationship with the entity, so you should be making only one disclosure and including all activities for that entity therein. All compensation is cumulative and the dates for the relationship should be for the start of the relationship to the end of the relationship, not for each activity.
For example, if your consulting and lecturing relationship started in January and the lecturing ended in March but the consulting is ongoing, you should use January for the start date and "ongoing" for the end date.
12. What if I don't know the exact amount of compensation or duration of OPA?
13. Do I disclose when I perform the OPA or wait until I am compensated?
14. How long do I have to disclose a newly acquired OPA (or FOI)?
15. Am I required to disclose OPA when payment is made to the University?
16. I have an appointment at the VAMC. Is that considered an OPA?
17. I have a 9-month appointment at UM. Do I disclose OPAs done in the summer?
18. I am on sabbatical or on leave. Do I need to disclose?
19. Why do I have to disclose unexercised stock options?
20. When do I need to enter compensation/reimbursement for travel?
Reimbursement of travel expenses is considered to be compensation. Therefore, travel associated with an OPA must be disclosed.
Further, PHS funded Investigators must disclose the occurrence of any reimbursed travel or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities.
This disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
Our DPS page contains directions and additional frequently asked questions to help users maneuver though the system. For specific questions, users can contact the DPS help line at (305) 243-0877.