Frequently Asked Questions
Conflict of Interest and Consulting Annual Reporting
The Reporting Process
A: The reporting period for 2014 is September 2 through October 10.
A: The Conflict of Interest Policy provides that employees may be subject to discipline for failure to report.
A: Yes. You can still report because you can access the on-line reporting through MYINFO remotely from any internet access.
A: The previous year—September 1 through August 31.
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
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.
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.
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.
Charitable or Professional Interests
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.
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.
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.
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)
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.
A: No. You have no participation in employment decisions concerning your daughter, so you need not disclose the relationship.
Intellectual Property Ownership
A: No. Royalties paid to inventors by MSU need not be reported as a potential conflict of interest.
A: Yes. And, you must report this on the Proposal Clearance Form for sponsored research which could affect or be affected by your 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.
Teaching & Tutoring
2012 Updated Policy Changes
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.
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.