Definitions

Annual Disclosure: (specifically for MSU)  Disclosing and certifying on the MSU Contract and Grant Administration (CGA) database all Significant Financial Interests that relate to one’s institutional responsibilities.

Conflict of Interest (COI): Situation where a person is trusted to act impartially ﴾to make unbiased professional decisions﴿, yet the person has personal interests that could influence or "bias" professional judgments and actions; situation where one’s actions and motives may be questioned because of competing interests.

Conflict Management Plan: Agreement that sets out limits and restrictions on the investigator for the purpose of reducing or eliminating a conflict of interest, and to ensure that the design, conduct, and reporting of research will be free from bias. Management plans may include the following (non-exhaustive list):

  • Periodic meetings between the investigator and her/his department/unit chair to review actions taken according to the plan
  • Public disclosure of FCOI when presenting or publishing
  • Disclosure to human participants in research
  • Appointment of independent monitor
  • Change to research plan
  • Change of personnel responsibilities
  • Reduction or elimination of interest.

Conflict Review Committee (CRC): Committee established by the MSU Policy on Faculty Conflict of Interest, and appointed by the Vice President for Research and Graduate Studies (VPRGS).  The purpose of the CRC is to review cases referred by the Faculty Conflict of Interest Officer (FCOIO) where a faculty member has disclosed an interest that may create a conflict of interest. The CRC makes determinations about the existence of a conflict of interest and recommends appropriate action to the VPRGS. 

Disclose: To provide requested information about the nature of personal SFIs to MSU delegated officials through the Office of Sponsored Projects / Contract and Grant Administration Conflict of Interest web portal at http:\\osp.msu.edu.

Disclosure: Information provided about the nature of SFIs at the OSP/CGA Conflict of Interest web portal.

Entity: A domestic or foreign, public or private, for-profit or not for-profit, business, organization, or association; including but not limited to, a corporation, limited liability company, partnership, trust, or proprietorship.

Financial Conflict of Interest (FCOI): Situation where a person has a Significant Financial Interest that could directly and significantly affect the design, conduct, or reporting of research ﴾e.g. NIH grants﴿.

Financial Interest: Anything of monetary value, whether or not the value is ascertainable.

Institutional Responsibilities: Responsibilities on behalf of MSU, including teaching or education, research, outreach, and service activities, both within and outside the University, in the general area of the investigator’s position expertise.

Investigator: The PI, Project Director any other person regardless of title or position, who is deemed responsible for the design, conduct, or reporting of research, including those working for sub-grantees, contractors, consortium participants, collaborators, or consultants.  (See guidance document on determining who is an "Investigator.")

Manage (a conflict of interest): To take action to address a conflicting interest to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias, and that the reputation and interests of the University, faculty and students are protected.

Management Plan (see Conflict Management Plan)

National Science Foundation (NSF): An independent federal agency created to promote the progress of science; to advance the national health, prosperity, and welfare; to secure the national defense. NSF is the funding source for approximately 20 percent of all federally supported basic research conducted by America's colleges and universities.

Public Health Service (PHS): Primary division of the U.S. Department of Health and Human Services. Agencies which are a part of PHS include:

  • Administration for Children and Families (ACF)
  • Administration for Community living (ACL)
  • Agency for Healthcare Research and Quality (AHRQ)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • Centers for Disease Control and Prevention (CDC)
  • Centers for Medicare & Medicaid Services (CMS)
  • Food & Drug Administration (FDA)
  • Health Resources & Services Administration (HRSA)
  • Indian Health Service (IHS)
  • National Institutions of Health (NIH)
  • Substance Abuse & Mental Health Services Administration (SAMHSA)

Agencies that also follow the PHS disclosure requirements are listed here: http://nrc59.nas.edu/pub/fcoi_agencies_phs_regs.html

Significant Financial Interest (SFI): A financial interest consisting of one or more of various types of financial interests that, when aggregated over the previous calendar year, exceeds $5,000. It includes not only your own personal interests, but also financial interests held with or by your immediate family (spouse, domestic partner, dependent child(ren), and other dependents) and with or by any legal entity that you or your family owns or controls. 

Significant Financial Interests Include: 

  • Income or payments of any kind totaling more than $5,000 over the last calendar year from a single entity;
  • Ownership greater than 1 percent of a single outside entity or ownership interests greater than $5,000 (e.g., stock);
  • Serving as a trustee for a trust or estate, or having a beneficial interest in a trust or estate with income from a single entity exceeding $5,000. (If the holdings of the trust are related to your MSU responsibilities, then the trust must be disclosed.)
  • Receiving or providing loan exceeding $5,000
  • Intellectual property rights or licenses with an established fair market value exceeding $5000 or which generate income of any value from other than MSU (including royalties from other domestic universities);
  • Unvalued options for stock or ownership of any value in a private company;
  • Serving on a governing or advisory board, or in a fiduciary or managerial role, or as a general partner with or without pay;
  • Receiving gifts (goods, property, or services, such as travel or other recreational or personal amenities) with value greater than $250.
  • Opportunity for tangible personal benefit.
  • PHS investigators only: Sponsored or reimbursed travel of any value.

Exceptions: The following financial interests DO NOT need to be reported: 

  • SFIs unrelated to your MSU Institutional Responsibilities;
  • MSU salary, remuneration by MSU, or other payments at MSU's behest (including from an MSU-approved practice plan);
  • Financial interests arising solely by means of investment in a mutual, pension, or other institutional investment fund over whose management and investments neither you nor any immediate family member has control;
  • Indebtedness from a bank, credit union, or other commercial lender;
  • SFIs from seminars, lectures, teaching engagements, or service on advisory committees or review panels paid by domestic (U.S.):
    • Federal, state, or local government agencies;
    • Institutions of higher education; 
    • Academic teaching hospitals and medical centers; or
    • Research institutes affiliated with an institution of higher education.
  • For non-PHS investigators only: SFIs from foreign (non-U.S.) nonprofit, government, or higher education entities. 

Subrecipient: A person, organization or company that receives part of the funds from a supported MSU project in return for performance of a prescribed part of the project activities,  i.e., a subcontractor.

Transactional Disclosure: Disclosure related to a specific proposal for research or funding.  For each proposal in the Research Administration system, investigators are required to specifically note whether any of their interests is related to the proposal.