Financial Conflicts of Interest Related to Grants and Sponsored Projects Policy

Purpose:

This policy helps identify and resolve actual and potential significant financial conflicts of interests solely related to grants, sponsored research, and sponsored projects at Winona State University (WSU) funded by federal agencies with specific conflicts of interest requirements.

Policy:

As external sponsors establish their own policies of significant financial conflicts of interests, Winona State University (WSU) must oversee and administer compliance with these requirements. This policy establishes WSU’s conflict of interest compliance framework solely for grants, sponsored research, and sponsored projects funded by federal agencies with specific conflicts of interest requirements.

Investigators and project directors who are involved in outside business or consulting activities must clearly separate their WSU and outside obligations to avoid concerns about appropriate use of WSU resources.

This policy applies to all Winona State University investigators and project directors and any sub-recipients, sub-contractors, and consortium members involved in research or project activities proposed for funding or funded by an external sponsor with specific conflicts of interest requirements.

The Vice President for Academic Affairs is responsible for overseeing compliance and administrative procedures related to significant financial conflicts of interest for grants, sponsored research, and sponsored projects funded by federal agencies with specific requirements.

Related Documents

• 42 CFR, Part 50, Subpart F – Promoting Objectivity in Research

• Minnesota State Colleges and Universities Procedure 1.C.0.1 Employee Code of Conduct

• Minnesota State Colleges and Universities Procedure 1.C.2 Fraudulent or Other Dishonest Acts

Related definitions:

[3-28] Financial Conflicts of Interest (FCOI):

Financial interests that could be reasonably determined to directly and significantly affect the design, conduct, and reporting of research or projects funded or proposed for funding by an external sponsor.

[3-28] Financial Interest:

Any remuneration (such as salary, payment for services such as consulting fees, honoraria, paid authorships) from an entity, value of equity interest (such as stocks, stock options, other ownership interests) in an entity, and income from intellectual property (such as patents, copyrights, royalties). Financial interests do not include:

• Remuneration paid by WSU to the employee, including salary, intellectual property rights, and royalties
• Income from teaching, seminars, lectures, advisory committees, or review panels sponsored by an agency including institutions of higher education and academic medical centers and teaching hospitals
• Equity interests or income from investments vehicles such as mutual funds and retirement accounts so long as the investigator does not directly control investment decisions made in these vehicles

[3-28] Institutional Responsibilities:

The investigator’s or project director’s responsibilities on behalf of WSU, including teaching, professional preparation and practice, scholarly activities, and service on institutional committees and work groups.

[3-28] Investigator or Project Director:

For the purposes of this policy, the principal investigator and co-investigator(s) or project director and co-director(s) involved in the design, conduct, and reporting of research results funded or proposed for funding by an external sponsor, and the investigator’s (s’) spouse(s), domestic partner(s), and dependent children.

[3-28] Significant financial interest (SFI):

An interest in an external entity that reasonably appears to be related to each investigator’s institutional responsibilities and is:

• With a public traded entity, the aggregate value of any salaries or other payments for services received during the 12-month period preceding disclosure, and the value of any equity interest during the 12-month period preceding disclosure, exceeds $5,000; or
• With a non-public traded entity, the aggregate value of salaries or other payments for services received during the 12-month period preceding disclosure exceeds $5,000; or
• With a non-publicly traded company, an equity interest of any value during the 12-month period preceding the date of disclosure; or
• Income related to intellectual property rights and interests not reimbursed through WSU.

Authorizing Policy/Subsequent Procedure:

• 3-28A Financial Conflicts of Interest Related to Grants and Sponsored Projects Procedure

History:

Date and Subject of Revisions: WSU Regulation 3-28 dated October 1, 2002; January 3, 2012

Adoption date: 02/28/2023
Implementation date: 02/28/2023