THE REPORTING PROCESS
Q: How long do I have to submit the report?
A: The reporting period is from September 4 through October 12.
Q: Will the reporting period be extended as it was in previous years.
A: No, all reports must be submitted by October 12.
Q: What if I fail to report?
A: The Conflict of Interest Policy provides that employees may be subject to discipline for failure to report.
Q: Will I get a copy of my report?
A: You can print a copy at the prompt when you complete the on-line report.
Q: I have no conflicts to report. Must I still fill out the Conflicts of Interest Form online?
Q: I am going to be away on sabbatical for the fall semester. Must I still report?
A: Yes. You can still report because you can access the on-line reporting through MYINFO remotely from any internet access.
Q: I just quit my MSU job. Must I report?
Q: What is the period of time covered by the report?
A: The previous year—September 1 through August 31.
Q: I am a classified employee. Do I have to report?
A: While classified employees do not have to submit an annual conflict of interest report, all employees, including classified, are subject to conflict of interest laws and policy and must disclose potential conflicts as they occur. State law and MSU policy require disclosure of any relationship that may conflict with your duties and responsibilities at MSU.
CONSULTING, OUTSIDE WORK, AND CONFLICTS OF INTEREST
Q: As a tenured faculty member I perform consulting in accordance with MSU’s consulting policy. Must I disclose my consulting as a potential conflict of interest?
A: Not usually. If you comply with the consulting policy in that you limit the time to the policy constraints, use no MSU resources or, if you do, you reimburse MSU for using them, you do not need report your consulting on the conflict of interest report. However, you will need to report your consulting on the annual consulting activities report.
Q: Are there any circumstances that would require me to report my consulting as a potential conflict of interest?
A: Yes. If your consulting could create a conflict with your duties and responsibilities at MSU, it should be reported as a potential conflict of interest. For example, if you perform sponsored research, the results of which could benefit or harm a company you consult for, then there is the potential for conflict and the relationship should be disclosed as a potential conflict of interest.
Q: I am a contract professional appointed at .65 FTE and I also work for another company as an employee. Must I disclose my other employment?
A: Only if the outside employment conflicts in some way with your duties and responsibilities at MSU. For example, if, in your work for your other employer, you performed consulting services to your MSU department, that would raise the potential for conflict and must be reported.
Q: I am a full time MSU employee and I have a second, unrelated job on the weekends. Must I report this as a potential conflict of interest?
CHARITABLE OR PROFESSIONAL INTERESTS
Q: I speak at my professional association’s annual conference and receive an honorarium of $200 plus travel expenses. Must I report that as a conflict of interest?
A: Generally ,no. However, here are special rules about reporting travel for researchers performing U.S. Public Health Service (including NIH) research that do not affect your annual reporting obligations. Those rules affect the reporting on the Proposal Clearance Form and require special reporting during research projects as well.
Q: I am hired as a consultant to speak at conference sponsored by a particular business and receive full payment for the speech rather than an honorarium, must I report that as a potential conflict of interest?
A: Only if the interests of the business paying you somehow conflict with your MSU duties—for example, if your sponsored research could harm or benefit that business. However, remember, you would have to report that speaking engagement on your consulting activities form. Again there are special rules related to U.S. Public Health Service (including NIH) researchers which may require disclosure on the Proposal Clearance Form and during the research project.
Q: I am a member of the board of directors of my professional association and my travel expenses to meetings are reimbursed, but I am otherwise unpaid. Must I report this?
A: No, except for researchers funded by grants from the U.S. Public Health Service (including NIH), and as noted below special rules require that they disclose reimbursed or sponsored travel. However, that disclosure is not made in the annual disclosure process, it is made as part of the sponsored research disclosure process, either on the Proposal Clearance Form or as the travel occurs during the sponsored research project.
Q: Are the rules related to payment by third parties for conferences and travel different under the new COI Policy?
A: Yes, but only if you perform research sponsored by the U.S. Public Health Service (including NIH). In that case you have special reporting obligations concerning payment for travel by third parties. These obligations do not affect the annual reporting process.
FAMILY MEMBERS (NEPOTISM)
Q: I am an academic department head. My spouse works as an adjunct in my department. Must I disclose this relationship?
Q: Will this mean that my spouse cannot work as an adjunct in my department?
A: It depends. If a suitable plan can be established to assure that you do not make employment decisions concerning your spouse, he/she may continue to work as an adjunct in your department. However, if you are the only person who can reasonably supervise your spouse and make employment decisions, it may not be possible for your spouse to be employed in your department.
Q: My daughter is employed as a research associate in a physics lab at MSU. I am an accountant in the English department. Must I disclose this relationship?
A: No. You have no participation in employment decisions concerning your daughter, so you need not disclose the relationship.
Q: I am a tenured faculty member and my spouse is also a tenured faculty member in my department. I have no involvement in employment decisions concerning my spouse. Must I disclose this relationship?
Q: I am an assistant coach and I am engaged to marry an assistant coach for another MSU athletic team. I have no involvement in employment decisions concerning my fiancée. Must I disclose this relationship?
Q: I am an inventor of MSU technology which has been licensed to third parties by MSU. I receive royalties. Must I report this as a conflict of interest?
A: No. Royalties paid to inventors by MSU need not be reported as a potential conflict of interest.
Q: I have an outside business that develops technology which could be affected by the sponsored research I do at MSU. Must I report this?
A: Yes. And, you must report this on the Proposal Clearance Form for sponsored research which could affect or be affected by your business.
Q: Can I continue with my business and do sponsored research related to my business?
A: If the potential for conflict can be managed through formal written plans and safeguards, you may be able to do both. But, that will depend on the particular situation and whether the potential for conflict can reasonably be managed.
2012 UPDATED POLICY CHANGES
Q: How do the changes to the MSU COI Policy impact my annual reporting?
A: Under the policy, you must report on the annual report Significant Financial Interests which directly relate to your University responsibilities. The updates to the policy have changed the monetary thresholds for determining a Significant Financial Interest (SFI). The old policy provided that the monetary interest in an outside business must be reported if it was $10,000 or greater. That amount has been REDUCED to $5,000. However, if the interest is in a privately held company (e.g., not a stock-exchange traded company) ANY interest in such a company related direct to your University responsibilities must be reported.
Q: Aren’t there other changes to the Policy?
A: Yes. However, most of those changes relate to reporting by sponsored research Investigators in in the Proposal Clearance Form. MSU sponsored research investigators received special training on the changes to sponsored research COI disclosure in April, 2012.
Q: I am a full-time adjunct English composition instructor and I also provide private English composition tutoring. Must I disclose my tutoring business?
Q: Can I tutor students in my classes as part of my tutoring business?
Q: I am a full-adjunct and I also teach courses on the same subject for another on-line university. Must I report this work?