Gifts, Honoraria, and Travel Support
Gifts or other forms of financial support can raise research security risks if there are any expectations that the donor will receive something in return for the gift. Gifts and other forms of financial support also have specific reporting and disclosure requirements, depending on whether an individual researcher or the University receives the gift.
Gifts, honoraria, and travel support to individuals
The rules regarding disclosure of individual gifts, honoraria, and travel support received by researchers can be complex. Different disclosure requirements apply between the University and federal research agencies. The following is a summary of key reporting requirements.
Generally, University researcher’s must disclose gifts, honoraria, and travel support to the University in accordance with the University’s Faculty Conflict of Interest and Commitment Policy and applicable reporting forms.
Disclosure to federal research agencies depends on the specific disclosure rules of the funding agency; however, some general reporting rules apply.
Gifts to an individual
Under the University’s Faculty Conflict of Interest and Commitment Policy and applicable reporting forms, receipt of payment or anything else of value from a foreign source, regardless of dollar value, must be disclosed. This includes gifts provided by a foreign source.
Researchers also have responsibilities under the University Code of Conduct and the URMC Industry Interactions Policy with respect to receipt of gifts.
Federal agencies generally do not require that researchers disclose unrestricted gifts. To meet the definition of a gift under federal agency requirements, the item or service provided to the researcher must be given without expectation of anything in return.
Travel support
Under the University’s Faculty Conflict of Interest and Commitment Policy, researchers funded through any unit of the Public Health Service (including NIH) or the Department of Energy must disclose any reimbursed or sponsored travel that is related to their institutional responsibilities. Exceptions to this disclosure requirement include travel that is reimbursed or sponsored by the University, Federal, state or local governmental agencies, U.S. institutions of higher education, research institutes affiliated with institutions of higher education, and academic teaching hospitals and medical centers.
Travel support paid by a foreign source may require disclosure to federal agencies as Current and Pending (Other) Support. If a University researcher receives travel support from an external entity to perform research activities, that travel support should be disclosed as Current and Pending (Other) Support to federal agencies. Conversely, if an external entity provides travel support to a University researcher to attend a conference or workshop (and not to perform research activities), that support does not require disclosure as Current and Pending (Other) Support to federal agencies.
Honoraria
Honoraria received from a foreign source must be disclosed under the University’s Faculty Conflict of Interest and Commitment Policy and applicable reporting forms.
Honoraria or other payments given to a University researcher for the purpose of conferring distinction or to symbolize respect, esteem, or admiration are not required to be disclosed to federal agencies.
However, if the “honoraria” is provided in connection with research activities, such as research oversight, supervision, or co-authorship, it must be disclosed as Current and Pending (Other) Support.
Gifts to the University
If a University researcher receives or is presented with a potential University gift in connection with their research, this should be reported to University Advancement to ensure proper handling, additional review by the relevant Dean’s Office, and reporting. Depending on the circumstances, the potential gift should be reviewed by the University’s Research Security Officer before it is finalized.
If a “gift” to the University is intended to support an employee’s research activities and is not fully unrestricted, the researcher may have reporting requirements to applicable research sponsors. For example, when financial support is presented as a “gift” but there are expectations that the donor will receive something valuable in return (such as specific research activities or research deliverables), then the “gift” to the University should be disclosed by the researcher as Current and Pending (Other) Support to federal agencies. This financial support would not be considered a “gift” and instead should be characterized as sponsored research, as discussed in the Guidelines on Gifts from Corporations. As described in those guidelines, donors are not entitled to research deliverables, early access to findings, or pre-publication review.
Review additional guidance on Current and Pending (Other) Support, including the compilation of agency specific requirements. You can also contact your ORPA Research Administrator for more information.