Category: Messages to Faculty, Messages to Staff

Title: Financial Conflict of Interest Policy Disclosure Process

Dear Members of the Georgetown University Community,

I am writing to let you know about the annual Financial Conflict of Interest Policy disclosure process that will begin next week and continue through the third week of March.  This will be rolled out sequentially by campus, starting with the Law Campus and Senior Leadership Group, followed by the Medical Center and University Services, and ending with the Main Campus.  In addition to this message, you will receive a message from your Campus Conflict of Interest Officer (listed below), which will explain the process in more detail.  Then, shortly thereafter, most of you will receive an email asking you to disclose and containing a link to the disclosure form in the GU-PASS system we use to manage FCOI Policy disclosure and review.  Please complete your disclosure promptly when you receive that email.  Not everyone is required to disclose, so if you do not receive the GU-PASS email, you are not required to make a disclosure.

(In the past, some employees have been concerned that the email from GU-PASS with the disclosure link was a phishing attempt.  If you have concerns about whether the disclosure link is secure, please contact the UIS Helpdesk, the University Information Security Office, or your Campus COI Officer.)

General Information About the FCOI Policy and Disclosure Requirements

Georgetown University’s Financial Conflicts of Interest Policy underscores the University’s fundamental expectation that our work will be conducted with objectivity and integrity.  The policy seeks to identify potential, actual or apparent financial conflicts of interest and provides processes for disclosure of such conflicts and for eliminating or, when appropriate, managing them.  It also addresses the special obligations that members of our community whose research or other work is supported by external funds have to protect and maintain the public’s or a funder’s trust.

All employees, including both faculty and staff, are responsible for understanding and complying with this policy and for making required disclosures.   

The FCOI Policy requires University employees to make an initial disclosure when they begin working at the University, an annual disclosure each year, and an updated disclosure at any point when their circumstances change. Many employees have financial interests that require disclosure, but most financial interests that result in conflicts can be managed effectively. What is important is not necessarily the financial interest itself but rather its disclosure and the development of a management plan, where necessary.

The particular questions you are required to answer in the system will depend on whether you are an investigator on sponsored research projects or a non-investigator (all other employees).  The system will provide you with the full definition of “investigator” and other key terms used in the Policy, but if you have questions you can refer to the definitions section of the Policy or contact the appropriate Conflict of Interest Officer, listed below.

Campus COI Officers and Contact Information 

We appreciate your cooperation in this important process.

Thank you.

Jim Ward
University Conflict of Interest Committee Chair