Material change from annual disclosure: Whenever significant financial interests, external activities, or internal responsibilities change materially from those described in the annual disclosure, the disclosure is to be updated as soon as possible, in writing. Updates are to be submitted according to the same procedure as the annual disclosures, described above. Whenever possible, individuals must attempt to disclose expected changes or newly anticipated conflicts before they occur, and seek advice from the Dean, CHR or VPRD on the restrictions that may result from any anticipated new significant financial interest, before the circumstances for such a financial interest occur. Whenever an application for funding of a new research project is submitted, the investigator is required to certify that he/she has submitted a complete and accurate annual disclosure, and that the new research project does not present the potential for any actual or apparent conflicts of interest not already identified in the annual disclosure.

Human subjects research protocols: Principal investigators and key research personnel involved in human subjects research at the School of Medicine are required to complete and submit Protocol-Related Conflict of Interest Disclosure forms or related screening forms to the CHR at the time of the submission of each protocol to the CHR. These disclosures are intended to supplement, not replace, the annual disclosure described above.

Ad hoc disclosures by those not required to file annual disclosures: Postdoctoral appointees, non-faculty employees other than designated senior administrators, and students are not required to submit annual disclosure forms unless they are responsible for the design, conduct, or reporting of research. They are required, however, on an ad hoc basis, to disclose potential and actual conflicts of interest relating generally to University research (including, for example, the use of research facilities and involvement of students in startup-company sponsored research), University financial decisions, and other matters whenever they arise. If there is any doubt about the existence of an actual or apparent conflict of commitment or conflict of interest, the individual is required to submit a disclosure for review by the Dean of the College/School.

The confidentiality of the disclosures is to be respected as far as possible. In particular, the information on the forms is not be shared with any person other than those who have a need to know.