Conflict of Interest or Commitment and Financial
Conflict of interest for Research
The Board of Governors of Central Missouri State University has established a policy for conflicts of interest that adheres to federal and state regulations. Federal funding agencies have established additional requirements for institutions receiving funds for research or other projects. Statutory references for both state and federal regulations appear in the Conflict of Interest Policy. For externally funded projects, project directors are responsible for making the appropriate arrangements to avoid violation of the state statute.
A disclosure must be completed prior to the university’s acceptance of the award or issuance of a purchase order, contract, or subcontract for the acquisition of goods and services. The disclosure statement is to be submitted to the OSP through the department chair, dean, or relevant unit administrator. Signatures on the General Financial Disclosure on Grantlink indicating no conflict of interest with the external organization shall suffice for negative disclosures. Positive disclosures must be indicated on the the General Financial Disclosure on Grantlink and a Disclosure Statement must be submitted as prescribed.
A conflict of interest relevant to an externally funded project may occur when a university employee’s affiliation with the external organization meets any one of the following criteria:
- The employee is an officer, partner, trustee, employee, advisory board member, or agent of an external organization or corporation either funding a project or providing goods and services under a project on which the employee is participating in any capacity.
- The employee is the actual or beneficial owner of more than five percent (5%) of the voting stock or controlling interest of such organization or corporation.
- The employee has dealings with such organization or corporation from which she/he derives income of more than $10,000 per year, exclusive of dividends and interest.
- The employee’s immediate family (spouse, parents, parents-in-law, siblings, children, other relatives living at the same address as the employee, or reported as dependents on federal income tax forms) meet any of the criteria stated in a-c above.
The Director of Sponsored Programs will review disclosures of potential conflicts of interest and determine whether the disclosure should be referred to the Ethics in Research Committee for resolution. The following guidelines shall be applied as conflict of interest disclosures are reviewed:
- Assure adherence to relevant federal and state statutes, university policies and procedures, and other university documents that may be deemed appropriate.
- Consider the nature and extent of the financial interest of the employee and the organization or activity.
- Give special consideration to the terms and conditions of award, agreement, contract, or other documents that may mitigate or complicate the given situation.
- Consult with and obtain additional information from the employee as may be helpful in resolving actual or potential conflicts.
- Act in a timely manner so as not to unduly delay the proposed project or activity.
The Faculty Senate Ethics in Research Committee shall convene as necessary to consider disclosures of potential conflicts of interest as prescribed in the Faculty Guide Section IV. This Committee may take one of the following actions:
- Approve the proposed project or activity;
- Disallow the proposed project or activity; or,
- Approve the proposed project or activity subject to appropriate modifications in either the proposed project or activity or the external organizational affiliation(s) of the employee or employee’s family.
The Public Health Service (PHS) has conflict of interest regulations (42 CFR Part 50 Subpart F, 45 C.F.R. Part 94) in response to the increase in relationships between researchers and industry market places. These revised regulations became effective in 2012 and have been adopted by the following agencies:
- Administration for Children & Families
- AHRQ-Agency for Health Care Research & Quality
- ATSDR-Agency for Toxic Substances & Disease Registry
- CDC-Center for Disease Control and Prevention
- FDA-Food & Drug Administration
- HRSA-Health Resources & Services Administration
- IHS-Indian Health Services
- NIH-National Institutes of Health
- Office of the Secretary
- SAMHSA-Substance Abuse & Mental Health Services
- Alliance for Lupus Research
- American Heart Association
- American Cancer Society
- American Lung Association
- American Lung Association of Michigan
- Arthritis Foundation
- JDRF-Juvenile Diabetes Research Foundation
- Lupus Foundation of America
- Susan G. Komen Foundation
The items required prior to submission for all federal and federal flow-thru money (except Department of Education) or other sponsors adopting the new FCOI regulations: Proposal Personnel List, General Financial Disclosure and CITI Training - Conflict of Interest. CITI FCOI Training is required prior to submission of the proposal and every 4 years thereafter.
If you have any questions regarding financial conflicts of interest, or if you are unsure if your research involves financial conflicts of interest, please contact UCM's research compliance officer at email@example.com.