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Disclosure Profile

WVU Policy BOG 1.4 may require one or more of the following disclosure forms detailing an employee’s outside activities and financial interests based on that individual’s roles and responsibilities at the University.

COI is moving to WRAP

All COI disclosures and review––Research COI, Institutional COI, Outside Consulting Arrangement approvals––are now consolidated into a one-stop disclosure process in WRAP.

Important COI changes in the new WRAP system are listed on WRAP training.

WRAP

Research COI

For all conducting research at WVU.

WRAP

  • Anyone engaging in research at WVU who meets the definition of Investigator.
  • “Investigator” means the project director or principal investigator/program director, co-investigator, collaborator, senior/key personnel, faculty, and any other person, regardless of title or position, who is responsible for the design, conduct, reporting, or proposing of research or other activity whether funded or unfunded. For the purposes of this rule, graduate and undergraduate students generally are not considered investigators. Postdoctoral scholars and fellows may be considered Investigators if designated as such by the principal investigator on a case-by-case basis.

  • Investigators must disclose all Significant Financial Interests (SFIs) reasonably related to their responsibilities at WVU. If an Investigator does not have any SFIs to disclose, they must submit a Research COI Disclosure Form stating they have no SFIs.
  • “Significant Financial Interest for Research" means a financial interest consisting of one or more of the following interests of an Investigator or family member of the Investigator that reasonably appears related to the Investigator’s institutional responsibilities:
    • With regard to any publicly traded entity, the value of any remuneration received from the entity in the 12 months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, that when aggregated exceeds five-thousand dollars ($5,000.00).
    • With regard to any non-publicly traded entity, the value of any remuneration received from the entity during the 12 months preceding the disclosure, that when aggregated exceeds five-thousand dollars ($5,000.00), or when the Investigator or family member holds any equity interest in the entity.
    • Any intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
    • For an Investigator who applies for or receives funding through a Public Health Service grant, cooperative agreement, or contract, any reimbursed or sponsored travel (i.e., paid on behalf of the Investigator rather than being reimbursed) that reasonably appears related to their institutional responsibilities. Excluded is travel that is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, or a medical center or a research institute that is affiliated with an institution of higher education.
    • The term Significant Financial Interest for Research does not include the following types of financial interests:
      • salary, royalties, or other remuneration paid by the university to the Investigator or family member if the Investigator is currently employed or otherwise appointed by the university;
      • income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency;
      • or income from service on advisory committees or review panels for a federal, state, or local government agency.

  • Investigators must have a Research COI Disclosure Form on file that is no older than one year. Investigators will be notified when their Research COI Disclosure Form has expired.
  • Investigators must update their disclosure within thirty (30) days of the development of a new Significant Financial Interest for research.

Research COI Disclosure Profile can be accessed and submitted in WRAP.

Institutional COI

For only.

WRAP

  • University Officials must submit an Institutional COI Disclosure Form.
  • "University Official" means university board members, president, campus presidents, vice presidents, vice provosts, deans, associate and assistant vice presidents and provosts, assistant and associate deans, general counsel, director of internal audit, and all employees within the Office of Technology Transfer.

  • University Officials must disclose Significant Financial Interests for Institutional Conflicts of Interest to the Office of Conflict of Interest Compliance. If a university official has nothing disclose, they must submit an Institutional COI Disclosure Form certifying that no Significant Financial Interests for Institutional Conflicts of Interest exist.
  • “Significant Financial Interest for Institutional Conflicts of Interest” means a financial interest consisting of one or more of the following interests of a university official or family member of the university official that reasonably appears related to the university official’s institutional responsibilities:
    • Equity or ownership interests held by the university official or a Family Member worth more than ten-thousand dollars ($10,000.00) in the aggregate in any publicly traded, for-profit organization. Excluded are equity interests held in mutual funds or retirement programs.
    • Any equity or ownership interest held in any for-profit organization that is not publicly traded.
    • Service as a member of a board of directors or other governing board of a for-profit organization, including service as a trustee or scientific advisory board member, service as an officer of the organization (whether paid or unpaid) or service as an employee by the university official.
    • Payments or a legal right to a payment, including royalty payments, resulting from technology transfer, licensing or any outside business activities that, for any single arrangement, exceeds ten-thousand dollars ($10,000.00) in the aggregate per year. Income from clinical care and tuition income are excluded from this calculation and the requirements of this Rule.

  • University Officials must have an Institutional COI Disclosure Form on file that is no older than one year (start date: July 31).
  • Each University Official must update their annual disclosure within thirty (30) days of the development of a new Significant Financial Interest
  • Each University Official must complete an initial disclosure form within sixty (60) days upon commencing employment.

Institutional COI Disclosure Profile can be accessed and submitted on WRAP.

Outside Consulting

Outside Consulting Arrangement Approval Requests and Annual updates can be submitted in WRAP under the “Pre-Approval Requests” activity in your Disclosure Profile

WRAP

Full-time faculty and non-classified staff engaging in  Consulting Arrangements outside of their employment responsibilities to the university on subjects that are within their area of professional expertise.

  • All Consulting Arrangements in which full-time faculty and non-classified staff are engaged must be disclosed in WRAP using the Pre-Approval Request under your Disclosure Profile.
  • “Consulting Arrangement” means any outside employment, arrangement, or contract where a full-time faculty and non-classified staff provides their expertise to a non-university third party as an independent contractor and in which the expertise is, directly or indirectly, related to the employee’s employment or job duties with the university. However, for full-time employees during their yearly appointment term, such outside Consulting Arrangements must, at minimum, meet the following requirements:
    • it must further develop the individual professionally or serve the community, state, or nation in an area related to the individual’s assignment or professional expertise;
    • it must not constitute a conflict of commitment with the individual’s university responsibilities, nor interfere with the individual’s teaching, research and service to the university;

Additional details about Consulting Arrangements can be found in BOG 1.4.

  • Outside Consulting Arrangement Approval Form
    • Prior to agreeing to any outside Consulting Arrangement, an individual must submit an Outside Consulting Arrangement Approval Form to the dean of their college or school or the vice president of their unit. If an individual reports directly to the president, the president must approve the Form.
  • Outside Consulting Arrangement Annual Disclosure Form
    • All Faculty and Non-Classified Staff who have engaged in outside consulting arrangements within the past fiscal year (i.e., July 1 to June 30) must submit an Outside Consulting Arrangement Annual Disclosure Form to the individual’s dean or vice president by August 31 each year.
    • The individual must sign and certify the form as accurate and complete. This form must, at minimum, summarize all Consulting Arrangements that the individual has participated in within the last calendar year providing for each arrangement individually, a brief description of the arrangement, the entity whom the arrangement is with, and the total time committed within the term of their yearly appointment.

  • Outside Consulting Arrangement Approval Form
    • The  Outside Consulting Arrangement Approval Form must be submitted to the employee’s dean of their college or school or the vice president of their unit. If an individual reports directly to the president, the president must approve the form.
  • Outside Consulting Arrangement Annual Disclosure Form
    • The Outside Consulting Arrangement Annual Disclosure Form must be submitted to the employee’s dean of their college or school or the vice president of their unit. If an individual reports directly to the president, the president must approve the form.