Disclosing Financial Relationships

As part of Mount Sinai’s institutional conflicts of interest (COI) requirements, Mount Sinai staff and faculty are required to disclose any prior, existing and potential future arrangements/ relationships/ activities that you or a related party have with outside entities, both commercial and non-commercial, whether paid or unpaid.

Disclosure is the first step in managing potential conflicts of interest. Mount Sinai’s Electronic Disclosure Management System (eDMS) is designed to assist faculty and staff in ensuring compliance with institutional policies and practices. Mount Sinai faculty, staff, and researchers are required to complete/update their eDMS Disclosure Profile to report their and their related party’s outside relationships/activities and financial interests. Disclosure of financial interests in relation to individual research projects are also required as part of the project submission process.

Mount Sinai faculty and employees are required to complete/update their Disclosure Profile in eDMS annually if they fall into any of the categories below, even if they have nothing to disclose:

Icahn School of Medicine at Mount Sinai:

  • All Mount Sinai faculty receiving a Mount Sinai paycheck (full time, part time, and per diem)
  • All Mount Sinai faculty members employed at a Mount Sinai hospital or affiliate (e.g., Elmhurst Hospital Center, Queens Hospital Center, James J. Peters VA Medical Center in the Bronx, etc.—click here for a complete list of Mount Sinai hospitals and affiliates)
  • All Mount Sinai ACGME and non-ACGME clinical fellows
  • All Mount Sinai postdoctoral research fellows, students/trainees, and staff involved with research
  • Any voluntary faculty or adjunct faculty involved with research and/or education and training of students, residents, and fellows
  • All IRB committee members
  • All adjunct faculty

Mount Sinai Health System:

  • All staff positions Director level and above
  • Staff leadership, management, and others who have influence over the purchasing process (e.g., consultants, Supply Chain, Finance, Pharmacy, etc.)
  • Staff from business areas who have routine interactions with vendors or access to confidential business information
  • All nursing administration, physician assistants, nurse practitioners, and others who are subject to CMS open payment reporting requirements—click here for a complete list of Open Payments Newly Added Covered Recipients | CMS
  • All Health System offsite practice management and physicians who do not have a faculty appointment

The eDMS Disclosure Profile is required to be completed within 45 days of hire, annually, and updated (within 30 days) if there are changes to your financial interests. The eDMS Disclosure Profile must be completed electronically via eDisclosure Management System (eDMS).

How to Disclose:

Go to eDisclosure Management System (eDMS)

Mount Sinai faculty, staff, and researchers are required to complete/update their eDMS Disclosure Profile to report their outside relationships/activities and financial interests. Examples of individual financial interests that must be disclosed include but are not limited to:

  • Founder/Co-Founder/Partner of any startup, private or public entity, including not-for-profit entities
  • Corporate Executive Leadership Roles (any senior executive leadership role with fiduciary responsibilities)
  • Board Service (Board of Directors, Board of Trustees)
  • Outside Employment
  • Other appointments (compensated or uncompensated, including Foreign Research Support/Collaborations)
  • Consulting or Other Professional Services
  • Editorial Services
  • Equity or Ownership Interest
  • Royalty Payments (though Mount Sinai or through another entity)
  • Divestiture and Cash Pay-out
  • Sponsored Travel
  • Prizes and Honoraria
  • Venture Capital

The following related party relationships (parent, spouse/domestic partner and/or dependent children) or activities should be disclosed:

  • Related parties with employment positions in the Mount Sinai Health System
  • Related parties whose outside employment, activities, or financial interests directly overlap with your role/activities at Mount Sinai (e.g. employment by a pharmaceutical company from which you receive research grants)
  • Related parties who could influence or whose financial interest could benefit from a relationship with Mount Sinai (e.g. management position or equity interest in an outside entity that does business or is seeking to do business with Mount Sinai including licensing of Mount Sinai technology).

Individual financial interests do not include:

  • Salaries from Mount Sinai
  • Salary support from grants (foreign grants excluded)
  • Membership on study sections and review of scientific proposals; for domestic not-for-profit or governmental extramural entities that sponsor not-for-profit scientific research (e.g., NIH)
  • Information about your previous employment if you were hired in the current year or last calendar year, unless you have an ongoing relationship with your prior organization or if the entity is a foreign university or company
  • 401K/403B retirement funds or shares held in mutual funds not controlled by you