Disclosures must be filed:
At the time of submission to the Office of Sponsored Program (OSP) of a proposal for funding
Within 30 days of discovering or acquiring a new Significant Financial Interest (SFI; defined below)
and (PHS/NIH Only)
At least annually, commencing with, and on the anniversary of, the date of award, during the period of award. This is important because it means that if you are an investigator on a submission that is currently being considered for funding by PHS, you will need to file a disclosure as soon as you are aware that an award is forthcoming, and no later than the issue date of the award, if that date is after the effective date of the new PHS policy, i.e., August 24th.