Policies, Procedures and Guidelines

Material Financial Interest

Created 08/24/2012
Last Revised Date 05/25/2022

The following outlines the CIRC’s Threshold for Reviewing Financial Interests.

Reviewable against entities that have adopted PHS equivalent thresholds (e.g. PHS, DOE, AHA):
  • ≥$5,000 in remuneration from an entity (includes non-profits), in aggregate

  • ≥$5,000 equity in publicly traded entity

  • Holding of any ownership interest or equity in a non-publicly traded entity (includes non-profits)

  • Travel reimbursed or paid for on behalf of an investigator other than by government agency or institution of higher education
Reviewable against all projects regardless of funding source:
  • ≥$10,000 in remuneration from an entity, in aggregate

  • ≥$10,000 equity or 5% ownership in publicly traded entity

  • Holding of any ownership interest or equity in a non-publicly traded entity

  • Receipt of royalties/compensation related to intellectual property rights and interests

  • An agreement with an entity that entitles an individual to future royalties related to intellectual property (IP) rights and the IP is used or evaluated in human studies research
Not reviewable by CIRC (Does not need to be disclosed on EPA Disclosure):
  • Income from seminars, lectures, teaching engagements, service on advisory committees or panels paid by U.S. federal/state/local government agency, or U.S. institutions of higher education

  • Income from investment vehicles, such as mutual funds and retirement accounts, as long as the individual does not directly control the investment decisions

  • Invention disclosures or patented intellectual property (unrelated to a licensing agreement)