6.4.1 Financial Conflict of Interest: Federally Sponsored Projects

Printable Version

Effective Date:

1-23-96

Revision Date:

6-22-18

University Policy Statement

In order to foster objectivity and integrity in research, Eastern Michigan University will comply with applicable federal and state regulations and statutes regarding financial conflicts of interest in research. Thus, it is the policy of the University to require investigators to disclose any significant financial interest that may present a conflict of interest in connection with federally sponsored projects.

Definitions

Conflict of Interest Committee (COI Committee) means the committee, appointed by the Provost and Executive Vice President for Academic and Student Affairs or their designee, who is designated to monitor implementation of this policy.

Financial Conflict of Interest means a Significant Financial Interest that the COI Committee reasonably determines could directly and significantly affect the design, conduct, or reporting of externally sponsored research. Conflicts of interest arise when an investigator is or may be in a position to influence University business, research, or other decisions in ways that could lead to any form of personal gain for the investigator (including their spouse and/or dependent children) or give improper advantage to others to the University's detriment. Conflicts of interest depend on the situation and not on the character or actions of the individual.

Financial Interest means anything of monetary value received or held by an Investigator or an Investigator’s Family, whether or not the value is readily ascertainable, including, but not limited to: salary or other payments for services (e.g., consulting fees, honoraria, or paid authorships for other than scholarly works); any equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights and interests (e.g., patents, trademarks, service marks, and copyrights), upon receipt of royalties or other income related to such intellectual property rights and interests.

Financial Interest does NOT include:

  1. Salary, royalties, or other remuneration from EMU;
  2. Income from the authorship of academic or scholarly works;
  3. Income from seminars, lectures, or teaching engagements sponsored by or from advisory committees or review panels for U.S. Federal, state or local governmental agencies; U.S. institutions of higher education; research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers; or
  4. Equity interests or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions made in these vehicles.

For Investigators, Financial Interest also includes any reimbursed or sponsored travel undertaken by the Investigator and related to their institutional responsibilities. This includes travel paid on behalf of the Investigator as well as reimbursed travel, even if the exact monetary value is not readily available.  It excludes travel reimbursed or sponsored by U.S. Federal, state or local governmental agencies, U.S. institutions of higher education, research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers, unless that entity is itself the subject of research by the Investigator.

Institutional Official means the individual within the Institution who is responsible for the solicitation and review of disclosures of significant financial interests, including those of the Investigator’s Family, related to the Investigator’s institutional responsibilities. 

Investigator means any individual who is responsible for the design, conduct, or reporting of sponsored research, or who is included on proposals for externally sponsored funding. This definition is not limited to those titled or budgeted as principal investigator or co-investigator on a particular proposal, and may include postdoctoral associates, senior scientists, or students. The definition may also include collaborators or consultants as appropriate. For the purpose of this policy, the term investigator includes the investigator’s spouse and dependent children.

Research means a systematic investigation, study, or experiment designed to contribute to generalizable knowledge.  The term encompasses basic and applied research (e.g., a published article, book or book chapter) and product development (e.g., a device or material).

Significant Financial Interest means a Financial Interest that reasonably appears to be related to the Investigator’s Institutional Responsibilities, and:

  1. If with a publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure, and the value of any equity interest during the 12 month period preceding or as of the date of disclosure, exceeds $5,000; or
  2. If with a non-publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure exceeds $5,000; or
  3. If with a non-publicly-traded company, is an equity interest of any value during the 12 month period preceding or as of the date of disclosure; or
  4. Is income exceeding $5,000 related to intellectual property rights and interests not reimbursed through the Institution, or
  5. Is reimbursed or sponsored travel, outside of the exclusions outlined above.

Sponsored Research means research at EMU supported at least in part through money and/or donated equipment by any organization or entity not directly affiliated with EMU.

University Practice

The institution’s practice is to comply with Federal regulations, which require institutions to have policies and procedures in place that ensure that investigators disclose any significant financial interest that may present a conflict of interest in relationship to federally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding, at the time an investigator becomes engaged in externally sponsored research, and annually thereafter. Institutions must certify compliance on each proposal, as well as develop specific mechanisms by which conflicts of interest will be satisfactorily managed, reduced, or eliminated, prior to the University's expenditure of any funds under an award. The institution must also maintain appropriate records. If a new or reportable conflict of interest arises at any time during the period after submission of the proposal through the period of the award, the filing of a disclosure is also required.

  1. Eastern Michigan University requires each investigator engaged in externally sponsored research, regardless of the sponsor, to submit financial disclosures. Disclosures must be made at the time of proposal submission or when initiating engagement in externally sponsored research (whichever occurs first) and annually thereafter.
  2. If investigators are added to a project subsequent to proposal submission, these investigators must disclose all financial conflicts of interest prior to initiating work on the project.
  3. If a new or reportable conflict of interest arises at any time during the period after submission of the proposal through the period of the award, the filing of a disclosure is also required.
  4. Disclosure of financial interests shall be made to the Institutional Official, or their designee, by submitting the Eastern Michigan University Financial Conflict of Interest Disclosure Form (available on the Office of Research Compliance website) to the Office of Research Compliance.
  5. At the time a proposal is submitted to a funding agency, the Director of the Office of Research Development and Administration shall certify that the University has implemented a written and enforced conflict of interest policy that is consistent with current federal guidelines.

The Institutional Official shall be responsible for developing and adhering to procedures consistent with this policy.

A COI Committee shall be charged with the responsibility for review of financial disclosures to determine whether a conflict of interest may exist, and to determine conditions or restrictions, if any, that should be imposed by the institution to manage, reduce, or eliminate such conflicts of interest.

Responsibility for Implementation

The Provost and Executive Vice President for Academic and Student Affairs has the overall responsibility for implementation of this policy. The Institutional Official, or their designee, is responsible for the daily administration of the policy.

Scope of Policy Coverage

This policy requires the principal investigator/project director, co-principal investigator(s) 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 to disclose any significant financial interest that may present a conflict of interest in connection with externally sponsored projects. 

Authority for Creation and Revision


Minutes of the Board of Regents, January 23, 1996
Minutes of the Board of Regents, June 22, 2018


Last Review Date: June 2018


University Policy Statement

In order to foster objectivity and integrity in research, Eastern Michigan University will comply with applicable federal and state regulations and statutes regarding financial conflicts of interest in research. Thus, it is the policy of the University to require investigators to disclose any significant financial interest that may present a conflict of interest in connection with federally sponsored projects.

Definitions

Conflict of Interest Committee (COI Committee) means the committee, appointed by the Provost and Executive Vice President for Academic and Student Affairs or their designee, who is designated to monitor implementation of this policy.

Financial Conflict of Interest means a Significant Financial Interest that the COI Committee reasonably determines could directly and significantly affect the design, conduct, or reporting of externally sponsored research. Conflicts of interest arise when an investigator is or may be in a position to influence University business, research, or other decisions in ways that could lead to any form of personal gain for the investigator (including their spouse and/or dependent children) or give improper advantage to others to the University's detriment. Conflicts of interest depend on the situation and not on the character or actions of the individual.

Financial Interest means anything of monetary value received or held by an Investigator or an Investigator’s Family, whether or not the value is readily ascertainable, including, but not limited to: salary or other payments for services (e.g., consulting fees, honoraria, or paid authorships for other than scholarly works); any equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights and interests (e.g., patents, trademarks, service marks, and copyrights), upon receipt of royalties or other income related to such intellectual property rights and interests.

Financial Interest does NOT include:

  1. Salary, royalties, or other remuneration from EMU;
  2. Income from the authorship of academic or scholarly works;
  3. Income from seminars, lectures, or teaching engagements sponsored by or from advisory committees or review panels for U.S. Federal, state or local governmental agencies; U.S. institutions of higher education; research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers; or
  4. Equity interests or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions made in these vehicles.

For Investigators, Financial Interest also includes any reimbursed or sponsored travel undertaken by the Investigator and related to their institutional responsibilities. This includes travel paid on behalf of the Investigator as well as reimbursed travel, even if the exact monetary value is not readily available.  It excludes travel reimbursed or sponsored by U.S. Federal, state or local governmental agencies, U.S. institutions of higher education, research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers, unless that entity is itself the subject of research by the Investigator.

Institutional Official means the individual within the Institution who is responsible for the solicitation and review of disclosures of significant financial interests, including those of the Investigator’s Family, related to the Investigator’s institutional responsibilities. 

Investigator means any individual who is responsible for the design, conduct, or reporting of sponsored research, or who is included on proposals for externally sponsored funding. This definition is not limited to those titled or budgeted as principal investigator or co-investigator on a particular proposal, and may include postdoctoral associates, senior scientists, or students. The definition may also include collaborators or consultants as appropriate. For the purpose of this policy, the term investigator includes the investigator’s spouse and dependent children.

Research means a systematic investigation, study, or experiment designed to contribute to generalizable knowledge.  The term encompasses basic and applied research (e.g., a published article, book or book chapter) and product development (e.g., a device or material).

Significant Financial Interest means a Financial Interest that reasonably appears to be related to the Investigator’s Institutional Responsibilities, and:

  1. If with a publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure, and the value of any equity interest during the 12 month period preceding or as of the date of disclosure, exceeds $5,000; or
  2. If with a non-publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure exceeds $5,000; or
  3. If with a non-publicly-traded company, is an equity interest of any value during the 12 month period preceding or as of the date of disclosure; or
  4. Is income exceeding $5,000 related to intellectual property rights and interests not reimbursed through the Institution, or
  5. Is reimbursed or sponsored travel, outside of the exclusions outlined above.

Sponsored Research means research at EMU supported at least in part through money and/or donated equipment by any organization or entity not directly affiliated with EMU.

University Practice

The institution’s practice is to comply with Federal regulations, which require institutions to have policies and procedures in place that ensure that investigators disclose any significant financial interest that may present a conflict of interest in relationship to federally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding, at the time an investigator becomes engaged in externally sponsored research, and annually thereafter. Institutions must certify compliance on each proposal, as well as develop specific mechanisms by which conflicts of interest will be satisfactorily managed, reduced, or eliminated, prior to the University's expenditure of any funds under an award. The institution must also maintain appropriate records. If a new or reportable conflict of interest arises at any time during the period after submission of the proposal through the period of the award, the filing of a disclosure is also required.

  1. Eastern Michigan University requires each investigator engaged in externally sponsored research, regardless of the sponsor, to submit financial disclosures. Disclosures must be made at the time of proposal submission or when initiating engagement in externally sponsored research (whichever occurs first) and annually thereafter.
  2. If investigators are added to a project subsequent to proposal submission, these investigators must disclose all financial conflicts of interest prior to initiating work on the project.
  3. If a new or reportable conflict of interest arises at any time during the period after submission of the proposal through the period of the award, the filing of a disclosure is also required.
  4. Disclosure of financial interests shall be made to the Institutional Official, or their designee, by submitting the Eastern Michigan University Financial Conflict of Interest Disclosure Form (available on the Office of Research Compliance website) to the Office of Research Compliance.
  5. At the time a proposal is submitted to a funding agency, the Director of the Office of Research Development and Administration shall certify that the University has implemented a written and enforced conflict of interest policy that is consistent with current federal guidelines.

The Institutional Official shall be responsible for developing and adhering to procedures consistent with this policy.

A COI Committee shall be charged with the responsibility for review of financial disclosures to determine whether a conflict of interest may exist, and to determine conditions or restrictions, if any, that should be imposed by the institution to manage, reduce, or eliminate such conflicts of interest.

Responsibility for Implementation

The Provost and Executive Vice President for Academic and Student Affairs has the overall responsibility for implementation of this policy. The Institutional Official, or their designee, is responsible for the daily administration of the policy.

Scope of Policy Coverage

This policy requires the principal investigator/project director, co-principal investigator(s) 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 to disclose any significant financial interest that may present a conflict of interest in connection with externally sponsored projects.