Financial conflict of interest
Helpful Information for WSU research employees regarding financial conflict of interest
The University recognizes that outside financial interests can facilitate opportunities for innovation, collaboration, and support. To ensure that its reputation and research programs are not compromised by even an appearance of inattention to this matter, Washington State University has put policies in place – consistent with federal guidelines – that require the reporting and management of the potential conflicts of interest of its faculty, administrators, and staff.
This Conflict of Interest web site makes available COI-related policies and procedures, resource and training materials, and other information on this important issue that will be of interest to the University community.
The Conflict of Interest Support Team provides assistance for WSU researchers and the Conflict of Interest Committee to facilitate and promote compliance with University, state, and federal policies and regulations regarding significant financial interests related to the objective conduct of research.
The Conflict of Interest review and management process consists of four stages: 1. Significant Financial Interest disclosure. 2. Conflict of Interest Application for a Management Plan. 3. Issuance of a COI Management Plan. 4. Annual reporting regarding the COI Management Plan.
Significant Financial Interest disclosure:
Investigators must disclose their Significant Financial Interests (SFI’s) at the following times:
1. When submitting a proposal related to HHS, NSF, DOE, or PHS FCOI applicable sponsors (direct or flow-through funding) and/or when the COI box is checked yes on the eREX Form
2. When a new SFI is discovered or acquired (e.g., through purchase, marriage, or inheritance)
3. Annually, when funded
4. When travel is reimbursed or sponsored (i.e., travel expense paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available), related to the Investigator’s WSU Responsibilities, with some exceptions
The University’s Financial Conflict of Interest Committee, supported by the Office of Research Operations and Support, will review the SFI’s and contact the Investigators if necessary.
Conflict of Interest Application for a Management Plan:
See “WSU Conflict of Interest Resources” below.
Issuance of a COI Management Plan:
When a real or perceived conflict of interest is disclosed and meets the threshold of significantly or directly affecting the design, conduct or reporting of the research, a management plan articulating how to mitigate the risks of impaired objectivity likely will be created. These plans are developed by the disclosing employee in close collaboration and under the guidance of the department/unit head and the Associate Dean for Research, Vice Chancellor for Research, or comparable official within the campus, college, or unit.
Management plans establish the operating parameters to be followed when a disclosing party engages an external business or entity in which the employee has a significant financial interest. Such external engagements include sponsorship of the employee’s university research, outreach or extension activities or certain other programmatic transactions. For example, consider a member of the faculty that starts a small business related to the research activities of their University appointment. If that faculty member’s company desires to contract with the University for research, outreach or extension activities then a management plan is required.
Additionally, management plans must be developed to determine how the University will make decisions about the procurement of employee-owned intellectual property, what the royalty arrangements will be and how objectivity will be assured regarding development and use of the licensed IP. See ‘Conflict of Interest Tech Transfer Management Plan Letter Template’ below.
Annual reporting regarding the COI Management Plan:
See “Conflict of Interest Management Plan Template” which details these reporting expectations, below.
WSU Conflict of Interest Committee:
- Reviews all pertinent documentation, including conflict of interest applications and management plans, relating to potential or actual financial conflict of interest cases based on federal and state law and University policy referred by the vice president for research.
- Recommends to the vice president for research what conditions and restrictions, if any, should be imposed by the University to manage the potential or actual financial conflict of interest.
Composition and tenure:
- Minimum of 6 faculty with 3-year terms, appointed by the president upon recommendation of the vice president for research.
- Chair shall be appointed by the president upon recommendation of the vice president for research.
- Ex officio, voting members:
Director, Office of Research Assurances, who serves as coordinator
Director, Intellectual Property Administration Office
AVP, Office of Research Operations and Support
- Quorum: more than 50% of the voting members
Responsible to the president through the vice president for research.
WSU Conflict of Interest Resources:
- WSU Executive Policy 27, “Washington State University Ethics, Conflict of Interest, and Technology Transfer”
- EP27 COI Definitions
- Conflict of Interest Committee Bylaws
- Conflict of Interest Application for a Management Plan Form
- Conflict of Interest Management Plan Template
- Conflict of Interest Tech Transfer Management Plan Letter Template
- Faculty Quick Guide for Conflicts of Interest
- Common Faculty Conflicts Document
- Boundaries Document for Researchers Working with their Start-up Companies
- NIH FAQ’s for Financial Conflict of Interest
- List of Agencies using the PHS FCOI Regulations
The federal Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) grant programs encourage the engagement of small business concerns (SBC) in federal research and development. WSU is not eligible to directly receive SBIR/STTR funding, but because collaborations between SBCs and research institutions are encouraged by the SBIR program and required by the STTR program, SBCs regularly seek WSU researchers to participate in their projects. WSU researchers may also want to start or grow their own SBC and consider SBIR/STTR funding important for the establishment and/or future development of their SBC.
- ORSO Guideline 9 titled “A Guide to Working with Industry Research Agreements with Washington State University”