May 30, 2024
I write to inform you of upcoming changes to the external activities disclosure form, effective for all disclosures made on or after June 3, 2024. Revisions were necessary to address gaps in our processes and comply with changing federal regulations.
Additional questions have been added to capture external activities that fall outside of the policy definition of significant financial interest. These activities require review to ensure compliance with Yale’s Faculty Handbook and sponsor policy. Increasingly, the federal government has an expectation that institutions receiving federal funding have a full understanding of faculty member’s external activities and that these activities fall within institutional guidelines, such as those related to time commitments and IP ownership.
Current guidance from federal funding agencies requires principal investigators and senior/key personnel to disclose all affiliations and associations with and/or research activities occurring at entities, other than Yale, when those affiliations, associations, and/or research activities relate to that individual’s research endeavors. Examples include appointments at other institutions regardless of status or compensation and research support from other institutions/entities, such as funding, equipment, materials, etc. The current expectation is that principal investigators and senior/key personnel also disclose to the funding agencies visiting researchers who are supported or funded by an institution/entity other than Yale, who support Yale’s principal investigator and/or senior/key personnel’s research endeavors.
Yale’s Policy on Conflict of Interest, Appendix D, addresses the policy and procedure for Conflict of Commitment. A conflict of commitment occurs when the commitment to external activities of a faculty or staff member that are not related to their University responsibilities adversely affects his or her capacity to meet University responsibilities.
The additional questions are focused on these areas of interest. Should you have any questions or need clarification as you complete your next disclosure, please contact the Research Integrity and Security Office at external.activities@yale.edu.
Sincerely,
Pamela S. Caudill
Senior Associate Provost for Research Administration
Office of Research Administration