Disclosing Financial Relationships

Disclosure is the first step in managing potential conflicts of interest. Our documented process assists our faculty and staff in ensuring compliance with our policies and practices. Each year, it is required to submit the Annual Report of Outside Relationships (“Annual Form”). Financial interests in relation to individual research projects are required as part of the project submission process.

An Annual Report of Outside Relationships (also called the “Annual Form”) must be completed online via Sinai Central by Mount Sinai faculty (both full time and part time, including voluntary faculty) and staff, disclosing all financial interests.

Others involved in Mount Sinai research must also complete an Annual Form.

  • In accordance with the Faculty Handbook, all Financial Interests of Covered Persons must be disclosed. Covered Persons include:
    • Investigators:
      • Principal Investigator (PI)
      • Co-Investigators, Sub-Investigators
      • Primary mentor on a Fellowship or Mentored Career Development Award
      • Faculty personnel, either key or non-key
    • Senior/Key Personnel:
      • The Program Director/Principal Investigator
      • Other Significant Contributor
    • Anyone else who is responsible for the design, conduct, or reporting of the research. This may include collaborators, consultants, students, trainees, technicians, postdoctoral fellows, and other key personnel.
    • Related Parties:
      • Spouse
      • Domestic partner
      • Dependent children
      • Investigators and key personnel are responsible for disclosing the Individual Financial Interests of their Related Parties
    • Voluntary Faculty if they:

      • Perform research at the Icahn School of Medicine at Mount Sinai, or
      • Participate on Institutional Committees, or
      • Perform paid administrative functions for a Department or the Icahn School of Medicine at Mount Sinai.

The Annual Report of Outside Relationships (“Annual Form”) 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 Annual Form must be completed electronically via Sinai Central.

How to Disclose:

Go to Sinai Central

Select the “COI” link on the left-side menu

Click “Annual Report of Outside Relationships”

Select the “paper icon” to left of your name in top row (current year)

All Covered Persons must disclose every Individual Financial Interest, regardless of value. All Covered Persons must disclose Individual Financial Interests of Related Parties. Examples of Individual Financial Interests that must be disclosed include but are not limited to:

  • Consulting Fees
  • Compensation for service on an Advisory Board (including scientific advisory boards) Officer’s/Director’s Fees
  • Honoraria for Lectures/ Teaching
  • Equity Interest of any kind and in any amount in a non-publicly or publicly traded Financially Interested Company
  • License fees, royalty income, or the right to receive such payments pursuant to a license, option, or other entitlement that is directly or indirectly related to the proposed research or services
  • Intellectual Property that is related to the proposed research or services
  • Travel (for National Institutes of Health-funded studies only): Federal rules require that all NIH-funded investigators disclose the occurrence of any reimbursed or sponsored travel, including the purpose of the trip, the identity of the sponsor/organizer, the destination and the duration, unless the trip is sponsored by a government entity or an academic medical center.

Individual financial interests do not include:

  • Salaries from Mount Sinai
  • Salary support from grants (foreign grants excluded)
  • Royalties received from Mount Sinai
  • Reasonable business meals and travel for scientific meetings consistent with Mount Sinai’s Policy on Relationships with Outside Entities. Exception: As indicated above, NIH-funded investigators must disclose such expenses if paid by an entity other than the government or an academic medical center
  • 401K/403B retirement funds or shares held in mutual funds not controlled by the Covered Person
  • Royalties paid to inventors by Mount Sinai