Public Disclosure Guidance
The ORC advises full and broad disclosure in presentations and publications as a key management strategy for conflicts of interest, actual and perceived. The scientific community and the public are best served by open publication and presentation of financial disclosures for readers, reviewers, and colleagues to evaluate. Full disclosure promotes transparency and removes the suspicion that something of relevance to objectivity is being hidden and allows readers to form their own opinions on the impact that the interest may have to the study.
Journals often contain a specific conflict of interest disclosure section that will outline requirements, such as relevant time period and scope of disclosure. Some may ask for a declaration of “no conflicts.” You should disclose interactions with any entity that could be considered broadly relevant to the work. For example, if your article is about analyzing the nutritional value in corn, you should report all of your associations with entities pursuing nutritional value in general, not just in the area of nutritional value in corn.
MSU employees, authors, and presenters should disclose financial interests in related outside entities and sources of support related to a presentation, public comment (including online), or any publication of research results, the provision of expert testimony on a subject, or if members of an audience would give weight to those interests in assessing the opinions, advice, or work they are receiving. This includes the disclosure of the financial interest (by entity name) in a business which owns or has a contractual relationship to the technology being reported or discussed or which sponsors the research being reported or discussed – see template examples below. Government agencies, research or academic universities, and other sources of public funding need not be disclosed.
Examples of conflicts that may require public disclosure in presentations and publications (would also necessitate transactional and annual reporting to MSU):
- If the research could affect your private interest/participation or if your private interest/participation could affect the research – OR – a perception of either case
- Financial interactions with any entity that could be considered broadly relevant to the work
- If members of an audience would give weight to those interests in assessing the opinions, advice, or work they are receiving
- Having received fees for consulting related to the research/industry related to the study
- Having received non-public sponsored research funding related to the study
- Having been employed by a related company
- Holding stocks or shares in a company which might be affected by the publication of your paper
- Having received non-public/non-academic funds reimbursing you for attending a related symposia, or talk
- Any other affiliations, funding sources, or financial holdings that might raise questions about possible sources of bias
- If required as a safeguard by your MSU Conflicts Management Plan
If there is any question, it is usually better to disclose a relationship than not to do so. Contact the ORC for evaluation assistance.
The following are examples of how a financial interest with an outside entity should be disclosed in presentations and publications of research results. This disclosure should occur in conjunction with an approved MSU Conflicts Management Plan or approved conflicts exemption:
Example #1 – Equity Interest and Outside Board Participation:
These studies were supported by a grant from NIH (Award #_______). Jane Doe has an equity interest in ABC, Inc., a company that may potentially benefit from the research results, and also serves on the company's Scientific Advisory Board. The terms of this arrangement have been reviewed and approved by Montana State University in accordance with its conflict of interest policies.
Example #2 – Multiple Author Interest, Matching Funds, and Outside Participation:
This study was funded in part by the Montana Board of Research and Commercialization Technology (MBRCT) #___ with matching funds from industrial partner ABC, Inc. John Doe is the scientific founder of ABC, Inc. and has an equity interest in the company. In addition, Bill Moe receives income from ABC, Inc. for serving on the Scientific Advisory Board. The terms of this arrangement have been reviewed and approved by the Montana State University in accordance with its conflict of interest policies.
Example #3 – Private Sponsored Research Funding & Related Consulting:
Dr. John Doe receives research funding from ABC, Inc., which is developing products related to the research described in this paper. In addition, the author serves as a consultant to ABC, Inc. and receives compensation for these services. The terms of this arrangement have been reviewed and approved by Montana State University in accordance with its conflict of interest policies.
Example #4 – Principal Investigator and Inventor Private Participation:
These studies were supported by a STTR partnership subcontract from ABC, Inc. Jane Doe is the inventor of intellectual property licensed to ABC, Inc. She also serves on the ABC Scientific Advisory Board. The terms of this arrangement have been reviewed and approved by Montana State University in accordance with its conflict of interest policies.