In response to a posting on Monday by Doug Wilkerson, it is my
understanding of the regulations that no public disclosure is required nor
needed in publications, etc. concerning significant financial interests if
disclosure is made and managed according to the established institutional
policy.  However, the regulations do require public disclosure of failure
to comply in all presentations/publications involving clinical trilals
where there was a significant financial interest that was not disclosed
according to the institutions policy.

Terry A. May, Ph.D.                       Voice:    520-523-6788
  Director of Research Administration     FAX:      520-523-1075
  Office of Grant & Contract Services     INTERNET: xxxxxx@nau.edu
  100 Babbitt Admin. Ctr., Box 4130
  Northern Arizona University
  Flagstaff, AZ  86011-4130