Investigator Significant Financial Interest Disclosure Policy for Sponsored Projects
These guidelines define general University policy and procedures regarding conflicts of interest in relationship to research or educational sponsored projects. Their purpose is to protect the credibility and integrity of the University's faculty and staff so that public trust and confidence in the University's sponsored research and educational activities is ensured.
In accordance with Federal regulations, the University has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by a financial interest of an investigator. Thus, the University requires that investigators disclose any significant financial interest that may present an actual or potential conflict of interest in relationship with a sponsored project.
A. Definitions
A potential Conflict of Interest occurs when there is a divergence between an individual's private interests and his or her professional obligations to the University such that an independent observer might reasonably question whether the individual's professional actions or decisions are determined by considerations of personal gain, financial or otherwise. An actual conflict of interest depends on the situation and not on the character or actions of the individual.
Investigator means the principal investigator/project director, co-principal investigator, and any other person at the University who is responsible for the design, conduct, or reporting of research or educational activities funded, or proposed for funding, by an external sponsor. In this context, the term "Investigator" includes the investigator's spouse and dependent children.
Significant Financial Interest means anything of monetary value, including, but not limited to:
- salary or other payments for services (e.g., consulting fees or honoraria)
- equity interest (e.g., stocks, stock options or other ownership interests)
- intellectual property rights (e.g., patents, copyrights and royalties from such rights)
The term does not include:
- Salary, royalties or other remuneration from the University;
- Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
- Income from service on advisory committees or review panels for public or nonprofit entities; or
- Financial interest in business enterprises or entities if the value of such interests do not exceed $5,000 (or $5,000 per annum if salary, fees or other continuing payments) or represent more than a 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's spouse and dependent children.
B. Guidelines
1. Each investigator is required to disclose the following significant financial interest:
(i) Any Significant Financial Interest of the Investigator that would reasonably appear to be directly and significantly affected by the research or educational activities funded, or proposed for funding, by an external sponsor; or
(ii) Any Significant Financial Interest of the Investigator in an entity whose financial interest would reasonably appear to be directly and significantly affected by the research or educational activities funded, or proposed for funding, by an external sponsor.
Regardless of the above minimum requirements, a faculty or Staff member, in his or her own best interest, may choose to disclose any other financial or related interest that could present an annual conflict of interest or be perceived to present a conflict of interest. Disclosure is a key factor in protecting one's reputation and career from potentially embarrassing or harmful allegations of misconduct.
2. Each investigator shall complete a Significant Financial Interest Disclosure Form and attach all required supporting documentation.
3. As required by federal regulation, all Significant Financial Interests must be disclosed prior to the time a proposal is submitted. All financial disclosures must be updated by Investigators during the pendency of the award, either on an annual basis or as changes are made to previously reported Significant Interests. If a new reportable Significant Financial Interest arises at any time during the period after the submission of the proposal through the entire period of any resulting award, the filing of a Disclosure Form is also required.
4. The Dean of the College in the case of faculty and the immediate supervisor in the case of staff shall conduct an initial review of all financial disclosure to determine if any disclosed Significant Financial Interest could affect the design, conduct, or reporting of the proposed sponsored project. If the initial determination is made that there may be potential for conflict of interest covered by this policy, then the Disclosure packet will be referred to the Provost. The Provost shall determine what conditions or restrictions, if any, should be imposed by the institution to manage actual or potential conflicts of interest arising from disclosed Significant Financial Interests.
5. The Investigator, in cooperation with the Dean, shall develop and present to the Provost and Academic Vice President a Plan that details proposed steps that will be taken to manage, reduce, or eliminate any actual or potential conflict of interest presented by a Significant Financial Interest. At a minimum the Resolution Plan shall address such issues as:
- Disclosure of significant financial interests;
- Review or research protocol by independent reviewers; and
- Monitoring of research by independent reviewers.
The Provost shall review the Resolution Plan and approve it, add conditions or restrictions, including the following:
- Modification of the research plan;
- Disqualification from the participation in all or portion of the research funded;
- Divestiture of significant financial interest; or
- Severance of relationships that create actual or potential conflicts of interest.
- The approved Resolution Plan shall be incorporated into a memorandum of Understanding that details the conditions or restrictions imposed upon the Investigator in the conduct of the project or in the relationship with the business enterprise or Entity. The Memorandum of Understanding shall be signed by the Investigator and the Provost. Actual or potential conflicts of interest will be satisfactorily managed, reduced, or eliminated in accordance with these guidelines prior to accepting any award, or they will be disclosed to the sponsoring agency for action.
- Records of investigator financial disclosures and of actions taken to manage actual or potential conflicts of interest, shall be retained by the Grants and Research Office until 3 years after the later of the termination or completion of the award to which they relate, or the resolution of any government action involving those records.
- Whenever an Investigator has violated this policy or the terms of the Memorandum of Understanding, the Provost shall recommend sanctions which may include disciplinary action ranging from a public letter of reprimand to dismissal and termination of employment.
C. Applicability
This policy shall be enforced with regard to grant awards from government agencies which regulate conflicts of interest. Certain agencies may add requirements that differ from this policy. In such cases the sponsor's requirements will prevail.
