When do I have to disclose travel?
If you are an investigator on any PHS-supported grant or contract, you need to disclose each instance of travel that is reimbursed or sponsored by an outside entity, when the amount of travel during the preceding 12 months reaches or exceeds $5,000 in the aggregate for a particular entity. (Note: This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.) Disclosures must be made within 30 days of reaching the $5,000 threshold and of every instance of sponsored or reimbursed travel occurring thereafter.
Do I need to disclose travel if I’m not an investigator on a PHS grant or contract?
No. Only investigators on PHS grants and contracts are required to disclose sponsored or reimbursed travel.
What is meant by “reimbursed” and “sponsored” travel?
When an entity purchases your airline or train ticket or pays for your hotel stay, that is “sponsored travel.” When an entity directly reimburses you for your purchase of transportation or lodging, that is considered “reimbursed travel.”
What if I don’t know the specific value of the sponsored travel I am disclosing?
eDisclose allows users to provide either the specific value, an estimate of the value, or a description of the travel costs covered by the entity. To determine whether the aggregate value of sponsored and reimbursed travel has reached $5,000, investigators should make their best efforts to learn the value of the sponsored and reimbursed travel.
Do non-faculty investigators such as research coordinators need to disclose sponsored or reimbursed travel if they’re listed on a PHS-sponsored grant? What if a research coordinator is a study team member on an IRB protocol?
All individuals who meet the definition of “investigator” on a PHS-supported research project must report their outside activities and financial interests. Under JHU’s conflict of interest policy, an investigator is:
- The project director or principal investigator and any other person responsible for the design, conduct, or reporting of research. Includes collaborators and consultants.
- All study team members on IRB applications.
The phrase “responsible for the design, conduct, or reporting of research” should be interpreted to mean any individual involved in the research who works independently enough to affect the objectivity of the design, collection, or analysis of research data or reporting of research results. In addition to faculty members, this may include graduate and post-doctoral trainees, research staff, consultants, or other collaborators. The definition of investigator is independent of whether or not an individual is employed or appointed by Johns Hopkins University. The ultimate determination as to who is considered an investigator in PHS-supported research is the decision of the PI of the project.
I am a consultant on an NIH grant to Johns Hopkins, and the grant paid for me to go to a conference. Do I have to disclose that?
No. Travel payments made by the institution do not need to be disclosed.
What if my travel is sponsored or reimbursed by a non-U.S. institution of higher education?
Only institutions of higher education chartered under U.S. law are exempt from the reporting requirements. Therefore, if you are an investigator on any PHS-supported grant or contract, you need to disclose travel that is sponsored or reimbursed by a foreign institution of higher education when/if the aggregate value of the travel sponsored or reimbursed by the institution reaches or exceeds $5,000.
What if an academic society or disease-advocacy organization pays for me to attend its annual meeting? Do I need to disclose this as sponsored or reimbursed travel? What if they waive my registration fee for the annual meeting?
If you are an investigator on any PHS-supported grant or contract and the organization pays (or reimburses you) for your flight or hotel stay, you need to make a disclosure when/if the aggregate value of the travel sponsored or reimbursed by the entity reaches or exceeds $5,000. Waiver of the registration fee does not need to be disclosed.
What if I travel to a meeting where dinner is included and the sponsoring entity buys an expensive bottle of wine? And what if they pay for my cab fare? What if they just pay for meals during my trip?
For the purposes of reporting travel-related expenses, you need to disclose only sponsored or reimbursed transportation and lodging. Please remember that the JHM Policy on Interaction with Industry prohibits acceptance of meal and other gifts from industry and, with limited exceptions, travel support from industry. Please see the policy for further information.
What if I extend a “disclosable” trip at my own expense? How do I disclose this? For example, I am traveling to Singapore to give a talk at a Singaporean University and the institution will pay for my transportation and two nights at a hotel. I am going to take a vacation and extend the trip for one week at my own expense.
You must disclose the transportation and lodging that are paid for by the Singaporean University.
If I take one trip at the invitation of multiple organizations, do I need to submit a disclosure for each entity from which I receive reimbursement/sponsorship? For example, I am invited to give talks at three different organizations in Germany and each will pay for about one-third of my travel and lodging expenses.
Yes, you need to disclose each organization’s sponsorship of your trip (provided the aggregate value of any travel sponsored or reimbursed by that entity over the past 12 months reaches or exceeds $5,000) and indicate, if possible, what each organization paid for.