Paid Travel That Could Be A COI

If you are an Investigator or Senior/Key Personnel on a project sponsored by a Public Health Service (PHS) agency, such as the NIH, and you received reimbursed or sponsored travel (i.e., that which is paid on your behalf and not reimbursed to you) related to your University responsibilities in the previous 12 months, federal regulations require you to disclose certain information about the travel. (42 CFR Part 50, Subpart F - Promoting Objectivity in Research)

Who must disclose paid travel?

Only people who are Investigators or Senior/Key Personnel on projects sponsored by a PHS agency. Investigator means the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants. Senior/Key Personnel means the PD/PI and any other person identified as senior/key personnel by the instituion in the grant application, progress report, or any other report submitted to the PHS by the Institution.

Travel that does NOT need to be disclosed

The requirement to disclose travel does not apply to travel that was reimbursed or sponsored by:

  • A Federal, state, or local government agency
  • An Institution of Higher Education, as defined by 20 U.S.C. 1001 (a)
  • An academic teaching hospital, a medical center, or a research instituiton that is affiliated with an Institution of Higher Education

SBIR/STTR Exclusion

The requirement to disclose reimbursed or sponsored travel does not apply to PHS-funded Phase I SBIR/STTR awards.