In response to Annette S. Pacilio's question:

>Do you require that all who submit to NSF or NIH file a disclosure
>form or do you make a judgement of who needs to file the form?

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At Northwestern University our Office of Research and Sponsored Programs
has enacted a policy where "each" investigator on a ALL research "proposal"
submissions completes a "Significant Financial Interest Disclosure Form"
regardless of whether the proposal is going to NSF or NIH, or a non-profit
foundation.  This policy is "a supplement to Northwestern University's
Policy on Faculty Conflict of Commitment and Conflict of Interest, and the
Policy on Staff Conflict of Interest".  According to our Office of Research
and Sponsored Programs  "it is intended to comply with regulations issued
in the July 11, 1995 Federal Register regarding mandated disclosures by
individuals having certain responsibilities with respect to sponsored
(i.e., externally funded) projects."

In addition to checking off a marked box on the previous "routing form" for this
institution, we now also complete the new "Significant Financial Interest
Disclosure" form for ALL submissions regardless of the funding agency.

Mary Kong, CRA
Director of Grant Development
School of Education and Social Policy
Northwestern University
2115 N. Campus Drive
Evanston, Illinois  60208-2610
(708) 467-1228
fax: (708) 467-1418
email: xxxxxx@nwu.edu
>