Guidance for consulting disclosure in Current and Pending (Other) Support

Yes. Senior/key persons must disclose any consulting activity that will require the senior/key person to perform research as part of the consulting activity.

It depends.

As the instructions for the Current and Pending (Other) Support Common Form state, the information is used “to assess the capacity or any conflicts of commitment that may impact the ability of the individual to carry out the research effort as proposed. The information also helps assess any potential scientific and budgetary overlap/duplication with the project being proposed.”

Even if your consulting does not involve performing research, it still must be included in Current and Pending (Other) Support if it is related to your research portfolio and “may have the ability to impact funding, alter time or effort commitments, or otherwise impact scientific integrity.”

In thinking about this disclosure requirement:

1. Consider if the consulting activity is related to your research portfolio. If not, there is no requirement to disclose. However, consulting likely will relate to your research portfolio because both are in your area of professional expertise.
2. Consider time and effort. Is your consulting activity consistent with Columbia’s conflict of commitment requirements described here? If not, you must disclose it, and also work immediately with your school to restructure the activity so that it is compliant.
3. Consider whether the consulting activity could otherwise affect funding or scientific integrity. For example, if you have disclosed the consulting activity on your Annual Financial Interest Report (i.e., your annual FCOI form) in Rascal, the disclosure has been reviewed and managed by the FCOI Committee, and you are in compliance with the management plan, then you would NOT need to disclose the consulting in Current and Pending (Other) Support. Similarly, if your consulting compensation is $5,000 or less in a 12-month period, and therefore below the University’s “significant financial interest” threshold, then you would NOT need to disclose the consulting in Current and Pending (Other) Support.

If you are not sure whether to disclose the consulting, err on the side of transparency and include it in Current and Pending (Other) Support.

Finally, the Common Form also requires that senior/key persons disclose any consulting activity with an entity that has provided a contract that requires the senior/key person to conceal or withhold confidential financial or other ties between the senior/key person and the entity, irrespective of the duration of the engagement. A standard clause that protects proprietary information shared with the consultant does not trigger this requirement, but any clause restricting the consultant’s ability to disclose the existence or nature of the engagement triggers a disclosure obligation in Current and Pending (Other) Support. This requirement applies regardless of whether the consulting activity itself involves research.

See Common Form Disclosure FAQs here.