University Disclosure Requirements

Georgia Southern employees must make specific disclosures or confirm that they have no disclosures to make. While these disclosures serve distinct purposes, there is some overlap. The Conflict of Interest / Conflict of Commitment disclosure might contain information that should be separately disclosed to meet other requirements. Refer to the information below to understand these disclosures and their timing. For further inquiries, contact the Office of Legal Affairs, Office of Research Integrity, or Internal Risk, Audit, and Compliance.

Conflict of Interest / Conflict of Commitment

The COI/COC disclosure, governed by the COI/COC Policy, is mandatory for all faculty and staff working a minimum of thirty (30) hours per week (or 0.75 FTE). It requires the disclosure and pre-approval of reportable outside activities. These disclosures must occur before engaging in the activity and annually thereafter. The policy identifies nine (9) categories of reportable outside activities, including:

1. Management or material interest in a business entity.
2. Running for or holding a public office.
3. Outside teaching appointments.
4. Outside research, writing, or editing in your field not part of your University duties.
5. Development of outside educational materials.
6. Royalties from licensing and copyright.
7. Expert witness or legal consulting.
8. Professional services related to your academic or professional field.
9. Leadership roles in outside organizations.

Disclosure Submission, Review & Approval Process:

Disclosures are submitted electronically by the employee for approval via the University Conflict of Interest/Conflict of Commitment Annual Disclosure form.  Every February, employees will receive a reminder to complete their mandatory annual disclosures. Additionally, employees may update their disclosure at any time by submitting a new disclosure form. 

For faculty members, the disclosure form undergoes a review process within the supervisory chain, adhering to approval guidelines, and is signed by the discloser’s chair, dean, and the Provost. For staff members, it follows approval guidelines and receives a signature from the immediate supervisor.

Approval is typically granted unless there are concerns about the outside activity conflicting with work duties, the presence of an actual conflict of interest that cannot be managed, or if the activity poses significant research or national security concerns.

Additional Resources:

• USG Policy on Conflicts of Interest and Conflicts of Commitment
• Office of Legal Affairs website

Financial Conflict of Interest

The University mandates FCOI disclosures before submitting proposals for sponsored or externally funded research, in compliance with federal regulations for federal grant research. Researchers are also obligated to maintain current FCOI training (required every 4 years) and Responsible Conduct of Research training (once during tenure) through the CITI platform before submitting sponsored research proposals.

Under the Research FCOI Policy, researchers must disclose significant financial interests held by themselves or immediate family members in commercial enterprises or with members of the research team. These disclosures aim to identify any potential influence on the proposed sponsored research program or impacts on its execution or completion. Research FCOIs can encompass activities and assets that fall outside the scope of the COC/COI policy, including personal assets of immediate family members related to research funding or funder interests.

Disclosure Submission Process:

 FCOI disclosures should be made before initiating any sponsored research project or being designated as key personnel on a sponsored research proposal. Furthermore, these disclosures must be updated annually for as long as you continue to submit proposals for sponsored research.

To streamline the disclosure process, submissions are made to the Research Services Office through the Cloud Express platform on the  FCOI website, which allows grant coordinators to review them in real time.

After your proposal or award is in the system, you’ll receive an email with a link to your disclosure. If you need to report a new event post-award, you can access the Cloud Express platform through the FCOI website.

Additional Resources:

• GS Research Financial Conflict of Interest Disclosure Policy
• Office of Research Integrity website
• Office of Legal Affairs website

State Business Transactions

State law necessitates that state employees disclose specific business transactions involving the State of Georgia or any of its agencies, including the University, on an annual basis by January 31st. These transactions can encompass dealings with a business entity in which the employee or a family member holds a minimum of 25% interest. Transactions need not be reported if each individual transaction amounts to less than $250.00 and the aggregate of all transactions over the past year is $9,000.00 or less. Staff members who receive personal compensation for teaching courses must report teaching transactions. If you have had no transactions with the State beyond your employment at Georgia Southern, you are not required to submit a report.

Disclosure Process:

Disclosures should be electronically submitted directly to the State of Georgia. Detailed instructions for submitting this report are available on the Georgia Government Transparency website. To file online, follow the instructions provided here. You can access the E-filing system here. Please note that you will need to obtain a filer ID and password via email before you can submit your report. If you have filed electronically in the past, your previous filer ID and password should still work.

State law necessitates that state employees disclose specific business transactions involving the State of Georgia or any of its agencies, including the University, on an annual basis by January 31st. These transactions can encompass dealings with a business entity in which the employee or a family member holds a minimum of 25% interest. Transactions need not be reported if each individual transaction amounts to less than $250.00 and the aggregate of all transactions over the past year is $9,000.00 or less. Staff members who receive personal compensation for teaching courses must report teaching transactions. If you have had no transactions with the State beyond your employment at Georgia Southern, you are not required to submit a report.

Additional Resources:

• Office of Legal Affairs website

Last updated: 9/22/2023