Faculty Handbook
MSU Conflict of Interest Policy: Frequently Asked Questions
Why was the MSU Conflict of Interest Policy revised?
The revisions to MSU’s Conflict of Interest Policy (now called the “Conflicts of Interest, Faculty/Academic Staff” policy) were intended primarily to (a) align the policy with the best practices of other CIC (Committee on Institutional Cooperation) institutions and (b) ensure compliance with new Public Health Service (PHS) requirements, which go into effect on August 24, 2012.
How has the policy changed?
The revised policy requires the annual reporting of significant financial interests (SFIs) that are related to an individual’s research, teaching, outreach or service responsibilities. The previous policy, by contrast, required faculty to self-report SFIs as potential conflicts arise.
The revisions also change the process by which disclosed interests are evaluated. Under the revised policy, reported SFIs will be assessed by the Faculty Conflict of Interest Officer (“FCOIO”). If the FCOIO determines that a disclosed interest may create a real or potential conflict of interest, the FCOIO will forward the disclosure to a faculty Conflict Review Committee (“CRC”) for additional assessment. If the CRC determines that a conflict of interest exists, it will develop a plan for its resolution or management. These procedures will help to promote consistency and objectivity in assessing whether disclosed SFIs create conflicts of interest.
How will the annual reporting requirement be implemented?
The annual reporting requirement of the revised policy will be implemented in stages, beginning with PHS and National Science Foundation (NSF) investigators, with university-wide implementation to occur by January 1, 2015. All individuals covered by the policy should continue to self-report potential conflicts as they arise until the annual reporting requirement is extended to them. Similarly, non-PHS and non-NSF investigators are required to report SFIs related to individual sponsored projects at the time a proposal is submitted or new funding results, as previously required.
What is the purpose of the staged implementation of annual reporting?
The gradual implementation of annual reporting will permit the university to develop the administrative procedures to review and manage the larger volume of disclosures that will result with the introduction of annual reporting.
When will the annual reporting requirement be implemented for PHS and NSF investigators?
The annual reporting requirement will be implemented for PHS and NSF investigators on August 24, 2012. For purposes of the PHS regulations, MSU’s “institutional Financial Conflict of Interest policy” consists of its Conflicts of Interest, Faculty/Academic Staff policy and the supplemental “Guidelines on Conflict of Interest Pertaining to Applications for NSF and PHS Research Support,” which is a supplement to the main policy. The Guidelines, which are currently being updated to ensure compliance with the PHS regulations, will be made publicly accessible on August 24, 2012.
How will covered individuals report potential conflicts of interest?
We anticipate that a web-based system will assist in the reporting of SFIs related to an individual’s MSU responsibilities. Individuals will be asked to briefly describe the nature of their involvement with each entity in which they have a significant financial interest, but no added documentation or information will be requested at the time of initial reporting.
How can I learn more information about the revised policy?
Prior to the beginning of the 2012-13 academic year, resources will be provided through workshops, training, group discussions and an updated website to help clarify expectations and requirements for reporting. Please avail yourself of these resources. If you have specific questions at any time, contact Terry May, Faculty Conflict of Interest Officer (mayte@msu.edu or 432-7140).