Frequently Asked Questions (FAQ)

Conflict of Interest

MSU is subject to multiple conflict of interest policies and regulations. The procedures regarding how we disclose and manage potential conflicts of interest pursuant to these various policies and regulations are dependent on multiple factors such as the agreement type, the nature of the individual relationships, sponsor type, etc. Below we have developed COI FAQs which are organized to cover four COI topics: 1) General (what, who, how to disclose); 2) State of Michigan COI law (Board of Trustees approval process) 3) Federal COI regulations; and 4) Small Business Research-SBIR/STTR programs.

  • General
    • What is a conflict of interest?

    A conflict of interest refers to a situation in which significant financial interest or other personal considerations may compromise or could appear to compromise a research’s professional judgment or integrity.

    • What financial interest must I disclose?

    Generally speaking, MSU faculty and academic staff must disclose any significant financial interest in and/or managerial control over an external entity.  In some instances, primarily related to federal awards, MSU faculty and academic staff must also disclose the financial interest of their spouse and dependent children.  Financial interests can be of various types (receipt of payments, ownership, equity, gifts, etc. ) and must be reported according to the entity or organization in which they are held or which provides the financial interest (e.g., a company, trust, non-profit organization, non-U.S. University, etc.). See “What Do I Need to Disclose

    • What does "entity" mean?

    “Entity” refers to a separate legal entity, which can be an individual, corporation or other organization.  In this context, we are referring to entities that are separate and distinct from MSU. For more specific help, see “What to Disclose” and what constitutes a significant financial interest (SFI). When you disclose an SFI, you must also provide information about the entity type and explain how the significant financial interest in the entity relates to your MSU responsibilities.

    • Who reviews reported Financial Interests?

    Financial interests disclosed in the MSU Research Administration COI portal by faculty and academic staff are initially reviewed by the Financial Conflict of Interest Information Officer (FCOIIO).

    • What is the process for reviewing a financial interest to determine whether a conflict of interest exist and reporting and management are required?

    The Financial Conflict of Interest Information Officer (FCOIIO) shall make an initial assessment regarding any potential conflict of interest. The FCOIIO will review the disclosed interest and make a preliminary determination as to whether or not the interest could reasonably be expected to affect, or be perceived to affect, a faculty member’s performance of his or her University responsibility. If the FCOIIO determines that a disclosed interest may create a real or potential conflict of interest, the FCOIIO will forward the disclosed Significant Financial Interest (SFI) to the Conflict Review Committee (CRC) for additional assessment. If the CRC determines that no conflict of interest exists, the CRC shall inform the faculty member and the SVPRI of the CRC’s determination in writing. If the CRC determines that a conflict of interest exists as a result of a disclosed SFI, the CRC shall develop a written plan for the resolution or management of the conflict of interest. The CRC may consult with the faculty member, the faculty member’s unit administrators, the FCOIIO, and appropriate representatives of central administration to develop and propose management plan to manage or resolve the conflict of interest.

    The FCOIIO shall submit the proposed management plan to the faculty member and the faculty member’s unit administrators for review and comment. If the faculty member does not agree with the CRC’s proposed management plan, the faculty member may file a written objection detailing the nature of his/her objections with the SVPRI within ten days of receiving the CRC’s proposed management plan. The CRC’s proposed management plan, any written comments submitted by unit administrators, and objections of the faculty member shall be submitted to the SVPRI. The SVPRI may accept the CRC’s proposed management plan or decide to implement an alternative management plan to address the conflict of interest. The SVPRI shall issue his/her decision within thirty days of his/her receipt of the CRC’s proposed management plan and any supplemental material. The SVPRI shall report his/her decision to the CRC, faculty member, unit administrators, and FCOIIO.

    In devising a management plan to address a conflict of interest, the CRC shall seek to employ the least intrusive management techniques that will resolve the ethical and legal concerns arising from the conflict.          

    The CRC may recommend to the Provost and SVPRI the issuance of specific guidelines to investigators and other faculty regarding common conflict of interest situations.

    Subjective: If a faculty member believes, or is concerned, that any financial or other interest held by the faculty member will affect the way he/she performs his/her duties at MSU, the conflict must be disclosed in writing under the conflict of interest policy.

    Objective: Even if the faculty member believes that his/her financial interest would not affect the exercise of his/her professional judgment, if the financial interest is such that an independent observer could reasonably question whether the faculty member’s professional actions or decisions are affected or determined by considerations of personal gain arising from that financial interest, the financial interest is significant enough for the faculty member to disclose it.

    • Does a faculty member need to report a significant financial interest involving a University-funded project or a non-funded project?

    Yes, if the faculty member has a financial interest or an opportunity for tangible personal benefit which could affect the independence of judgment with which the faculty member performs the research. For example, if a faculty member has a significant financial interest in a company that will be materially affected by the outcome of a University funded research project conducted by that faculty member, that would be a reportable conflict of interest.

    • I have reported a significant financial interest that is related to an MSU project that I am working on. Do I need to disclose this interest to those who work on the project (including students)?

    Yes, you must disclose your personal interest in the entity to students, fellows, trainees, and other research workers supervised as an institutional activity when their efforts relate to the University project. Additionally, on an annual basis please inform and assure students, fellows, trainees, and other research workers that they may address concerns privately with the Chair (or other individual responsible for graduate programs) if any concerns arise due to your relationship with the entity.

    • Can income from consulting or other work approved under MSU’s Outside Work for Pay Policy form the basis for a reportable financial interest under the Policy?

    Yes. Such income is a financial interest which should be disclosed if it totals more than $5,000 in a calendar year from a single entity.

    • Is an Outside Work for Pay Policy form or a Travel Authorization form a substitute for completing a Conflict of Interest disclosure?

    No. You must still complete a disclosure.

    • What if I receive an honorarium as part of my travel? Do I disclose it as an SFI?

    Yes, if the honorarium meets or exceeds the $5,000 de minimus criteria (aggregated over the calendar year, from a single payer).  The honorarium would be disclosed as a payment and not as part of the travel reimbursement.

    • When do I need to make a disclosure?

    Annually: Disclosures must be completed no later than one year after your initial disclosure or last annual disclosure, and every 12 months thereafter.

    Project based: PHS/NSF regulations require that each institution and investigator applying for, receiving, or being supported by PHS/NSF funds be compliant with PHS/NSF rules regarding training and disclosure prior to applying for funds and the establishment of conflict of interest management plans prior to the expenditure of funds.

    Revising Disclosures: Disclosures must be updated within 30 days of acquiring or discovering any new significant financial interest. Additionally, any Project or Travel disclosure will prompt you to update your Annual disclosure.

    • What MSU Unit is responsible for gathering information related to financial interest?

    The Conflict of Interest Office is managed by the Faculty Conflict of Interest Information Officer (FCOIIO) (fcoiio@msu.edu). This Office has the responsibility for development of policies and procedures related to the identification and disclosure of significant financial interests, and the initial determination of potential conflicts of interest. The Office of Regulatory Affairs has overall responsibility of ensuring compliance with federal regulations governing conflicts of interest.

    • I don’t want everyone to know my finances. Will this information be kept private?

    MSU respects the confidentiality of private financial information and other information reported by faculty and will not release this information publicly unless:

    • It is legally required to do so.
    • The resolution or management of the conflict of interest requires public disclosure of the information.
    • The faculty member consents to its public disclosure.
    • The Public Health Service requires MSU to inform the public on our website that information regarding conflicts related to PHS funding is available to the public. When requested, MSU must provide the information within 5 working days.

    • To whom does the Policy apply?

    The Policy applies to individuals appointed through the academic personnel system with research, teaching, outreach, or service responsibilities at MSU.  The Policy also applies to individuals who have independent responsibility for proposing, conducting, or reporting the results of MSU research and other sponsored projects. Faculty and research leaders will need to determine which individuals in their group meet these definitions. An annual disclosure must be completed within 12 months of your initial/previous disclosure, regardless of whether you are applying for grants.

    Examples of those who are required to disclose include:

    • Fixed term and tenure track professors
    • Postdoctoral fellows
    • Research associates
    • MSU extension positions (e.g. program directors, specialists, etc.)
    • This does not include (unless they are working on a PHS or NSF project):
    • Professors emeritus
    • Lecturers
    • Students who are listed as Key Personnel

    While the institutional policy will apply to everyone, some federal agencies and private funding organizations have specific rules and regulations which must also be applied.

    • Do different colleges at MSU have different rules?

    Each college (or relevant non-college unit) is encouraged to prepare, in consultation with the FCOIIO, a supplement to the conflict of interest handbook, with frequently asked questions, that addresses conflict of interest issues specific to the disciplines and activities of the faculty of that college. A college may also adopt its own addendum to this Policy to address specific conflict situations which occur in that college. Please confer with your chairperson or dean to determine if additional standards have been implemented in your college.

    • Are graduate and other students required to disclose interests?

    While the policy is addressed to faculty and academic staff, it does apply to other individuals, including graduate or undergraduate students “who have independent responsibility for proposing, conducting, or reporting the results of MSU research and other sponsored projects.” This responsibility would be determined by the Project Director or Principal Investigator, who would identify the student as Key Personnel within the Proposal Development document. In that case, the student would be required to disclose any related significant financial interest and resolve any conflict of interest. Since students are not MSU employees, they cannot access the online portal; contact OSP/CGA or fcoiio@msu.edu for assistance. Please see the Forms tab.

    • What happens if I have a conflict of interest?

    The FCOIIO, with the Senior Vice President for Research and Innovation and/or the Conflict Review Committee (CRC) make a determination of appropriate action, usually the development of a conflict management plan.

    • What is a Conflict Management Plan?

    It is an agreement that sets out limits and restrictions on the investigator for the purpose of reducing or managing a conflict of interest, and to ensure that the design, conduct, and reporting of research will be free from bias or apparent bias. Management plans may include the following requirements (non-exhaustive list):

    • Public disclosure of a financial conflict of interest: when presenting or publishing research; to staff members working on the project; to MSU’s Institutional Review Board, etc.;
    • Disclosure to human subject participating in research;
    • Appointment of an independent monitor empowered to take measures to protect the design, conduct, and reporting of the research against bias;
    • Modification of the research plan;
    • Change of personnel responsibilities or disqualification of personnel from participation in all or a portion of the research; 

    A proposed conflict management plan is reviewed with the individual and his/her unit director before assessment and final approval by the Senior Vice President for Research and Innovation. Conflict Management Plans are periodically reviewed for compliance and updating as appropriate by the FCOIIO and staff.

    • What happens if I fail to file a disclosure required under the Policy?

    Without a required disclosure, an application for a project will not be allowed to be submitted.

    A faculty member who violates this Policy is subject to disciplinary action. The SVPRI shall establish a mechanism, after consulting with the FCOIIO, for investigating concerns or allegations regarding significant financial interests and other opportunities for tangible personal benefit of faculty which are not reported as required under this Policy.

    The Public Health Service, National Science Foundation and other funding agencies may have additional rules and regulations regarding non-compliance with their policies and regulations.

    • What happens if I make a mistake and forget to disclose something?

    If you made a mistake, return to the Research Administration System portal and update your disclosure.  After updating, you must re-certify your disclosure.   If you have further questions, contact the Conflict of Interest office.

    • Can MSU faculty or staff represent the company (they have an interest in) in subaward/contract negotiations with MSU?

    The involved employee is prohibited from participating in negotiations between MSU and the company. The employee may not represent either party in the transaction (MCL Act 317 of 1968, Subsections of 15.322)

    MSU is committed to full disclosure and appropriate management of conflicting interests in all activities, including sponsored projects. Multiple laws, regulations, and policies govern conflicts of interest.

    Please note if student participation is planned, the faculty member must obtain written permission by the Dean and Graduate School based on justification by Faculty Member and endorsement by his/her Chair to serve as the dissertation or thesis chairperson of any graduate committee for a student who is employed concurrently by the Small Business, funded by the Small Business or appointed or employed by MSU to carry out routine technical services for the Small Business.

    • Can students work for a company in which their MSU advisor has a financial interest?

    A student may work for a company in which their MSU advisor has a financial interest if the Faculty Member obtains written permission by their Dean based on justification by Faculty Member and endorsement by his/her Chair.

    • Can I be the PI for an entity outside of MSU?

    To do so, you would need to reduce your employment at MSU accordingly (or have an employment agreement between MSU and the entity for the appropriate effort). Additionally, you would not be able to serve as MSU subaward PI.

    • What are the Conflict of Interest guidelines if I am an MSU Faculty Member and have a personal financial interest in a small business intending to conduct work with MSU?

    While MSU participation in small business research and development is encouraged, conflicts of interest may arise when a Faculty Member or project Key Personnel has a personal interest in a small business.  For purposes of this FAQ, a personal interest in a small business means an MSU Faculty Member is a company officer or has a controlling interest or control gained through shareholder rights.  MSU's Faculty/Academic Staff Conflict of Interest Policy addresses conflict of interest in research generally, however additional guidelines apply to Faculty participation in small business research and development in which they, or their family, hold a personal interest.  The following are basic guidelines for all MSU small business research in which a Faculty Member or project Key Personnel holds a personal interest in the small business. Additional management may be required.

    1. The Faculty Member or project Key Personnel holding a personal interest in a small business intending to conduct work at MSU must take the following actions:
      1. Report to the Faculty Conflict of Interest Information Officer any change concerning his/her personal interest in the small business within 30 days or initiation of any new activity on behalf of MSU that relates to the small business as soon as it occurs;
      2. Request approval to undertake outside work related to the small business according to the Outside Work for Pay Policy and not enter into an independent consulting agreement with the small business that conflicts with MSU Policies;
      3. Disclose his/her personal interest in the small business to students, fellows, trainees, and other research workers supervised as an institutional activity when their efforts relate to those of the small business;
      4. Disclose his/her personal interest in the small business in publications and academic presentations from his/her laboratory/working group where such disclosure is appropriate and required;
      5. Request Dean’s approval to use MSU equipment and facilities in support of the small business, including the provision of routine testing services unless under approved subcontract;
      6. Discuss with the Chair or Dean any situation where a request or requirement by the small business might constrain the Faculty Member’s work, including the freedom to present or publish;
      7. Meet annually with his/her Chair to review the extent of his/her personal interest in the small business and its relationship to his/her institutional activities;
      8. Forward requests for purchases from the small business to Purchasing for review and approval; and
      9. Obtain written permission by the Dean and the Graduate School based on justification by Faculty Member and endorsement by his/her Chair to serve as the dissertation or thesis chairperson of any graduate committee for a student who is:
        1. Employed concurrently by the small business;
        2. Funded by the small business; or
        3. appointed or employed by MSU to carry out routine technical services for the small business.
    2. The Chair of a Faculty Member holding a personal interest in a small business intending to conduct work at MSU must take the following actions:
      1. Meet with Faculty Member annually to discuss the status of his/her institutional teaching, research, and service activities, and the activities of his/her laboratory/working group, that relate to the Small Business. As part of these discussions, the Chair will determine the following:
        1. whether there has been a change in Faculty Member’s personal interest in the small business and its relationship to his/her institutional activities;
        2. whether there has been a change in laboratory/working group personnel conducting research or other institutional activities that relate to the small business and/or require approval by an institutional review board;
        3. whether Faculty Member has disclosed his/her personal interest in the small business to students, fellows, trainees, and other research workers supervised as an institutional activity when their efforts relate to the Small Business;
        4. whether Faculty Member has disclosed his/her personal interest in the small business in pertinent publications and academic presentations from his/her laboratory/working group;
        5. whether Faculty Member’s request(s) to undertake outside work for pay need(s) to be updated; and
        6. whether Faculty Member has developed other personal interests in companies outside of MSU that create possible conflict situations.
      2. Annually inform and assure students, fellows, trainees, and other research workers in Faculty Member’s laboratory/working group that they may address concerns privately with the Chair (or other individual responsible for graduate programs) if any concerns arise due to Faculty Member's relationship with the small business; and
      3. Meet annually with the Dean (following the Chair's annual discussion with Faculty Member) to review Faculty Member's efforts related to the small business to jointly ensure compliance with these guidelines.
  • State of Michigan Law and Board of Trustees Approval

    Under MI law MSU Board of Trustee approval is required for certain contracts at MSU.  In order to comply with MI law, MSU employees must disclose ownership interests in or managerial control over outside legal entities. When conflicts/interests exist, Boards of Trustee review and approval is necessary.

    • Who must disclose outside interests?

    MSU employees with an MSU appointment that exceeds 24 hours per week.

    • What must be disclosed?

    MSU employees must disclose;

    • Any controlling interest in any private company (Sole Proprietor, Partnership, LLC, PLC, etc.)
    • An ownership interest in any publicly traded for-profit corporation if the stock value exceeds $25,000.00
    • Director or Officer (i.e. President, Vice President) in any corporation (for-profit and non-profit)
    • Any Trust in which the MSU employee is a beneficiary or trustee

     

    • What scenarios require Board of Trustees’ review and approval?
       
    • When a contract is proposed between MSU and a company in which an MSU employee has a controlling interest or serves as an officer or as a board member; or
    • If an MSU employee has an ownership interest in a publicly traded corporation that exceeds $25,000.00 and the MSU employee will participate in the sponsored activity as an MSU employee.

    • How does the Board of Trustees’ approval process work?

    The Board’s review and approval processes occurs in two stages.  The first stage (“1st Read”) takes place at a public Board meeting and is intended to identify the MSU employees’ interest in the legal entity.  At 1st Read, the identity of the employee, and the name of the entity are publicized. The second stage (“2nd Read”) takes places at a subsequent public Board meeting and is intended to disclose the terms of the specific contract under review.  At 2nd Read the names of the parties, the terms of the agreement, the financial consideration, the MSU services and facilities involved, the MSU staffing necessary to perform the activity and the nature of the MSU employee’s interest in the entity are disclosed.  Please note, 1st Read is only required on the initial disclosure of the MSU employee’s interest.  Subsequent contracts with the same entity only require 2nd Read.  

    • What are the 2020 Board of Trustees COI deadlines?
     

    Final Date to provide OSP, Business Connect or FCOI Office with Board agenda item

    Agenda Items due to OGC to get BOT Approval

    BOT Meeting Dates Contracts Approved

    Wed, Dec 11, 2019

    Friday, December 13, 2019

    February 14, 2020

    Friday, Feb 17, 2020

    Monday, Feb 24, 2020

    April 17, 2020

    Friday, April 24, 2020

    Monday, April 27, 2020

    June 24, 2020

    Friday, July 17, 2020

    Monday, July 20, 2020

    September 11, 2020

    Wed, Sept 2, 2020

    Friday, Sept 4, 2020

    October 30, 2020

    Friday, Oct 23, 2020

    Monday, Oct 26, 2020

    December 18, 2020

     

    Example Scenarios:

    • I am a faculty member at MSU and recently created a small business. I intend for this small business to work with MSU. What do I need to do?

    Immediately update your COI disclosure with this information. If this entity intends to do business with MSU, contact the FCOII Officer (fcoiio@msu.edu) or the Office Sponsored Programs/Business Connect to add this entity to the next Board of Trustees’ meeting agenda (see the FAQ’s for deadlines).  Once we know that MSU will be contracting with the entity, the forthcoming contract must go for “2nd Read” before the contract can be signed. The “2nd Read” must be added to a Board of Trustees meeting that is subsequent to the “1st Read”.

    • In October, I was appointed as the President of a non-profit organization. What do I need to do?

    Immediately update your COI disclosure with this information. If this organization intends to do business with MSU, contact the FCOII Officer (fcoiio@msu.edu) or your Sponsored Programs contact to add the organization to the December Board of Trustees’ meeting agenda. Please note, the deadline for adding items to the Board agenda is much earlier than the Board of Trustees meeting date. Please see the FAQ’s above for a specific timeline.  Once we know that MSU will be contracting with this organization, the forthcoming contract must go for “2nd Read” before the contract can be signed. Because the “1st Read” was done in December, the earliest the “2nd Read” could take place is the following February. 

  • Federal Regulations

    2 CFR Part 200- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires that Federal awarding agencies establish conflict of interest policies for Federal awards. The non-Federal entity must disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity in accordance with applicable Federal awarding agency policy. Due to this, Federal agency policies can vary slightly. Two of our larger Federal funding agencies, PHS (DHHS/NIH) and NSF have specific policies that we must adhere to most frequently.

    • Do travel reimbursements need to be disclosed?

    Disclosure of sponsored travel is only required for PHS investigators.  PHS investigators need to disclose all travel at any value except travel reimbursed or sponsored by MSU funds, federal, state, or local government agencies, or domestic institutions of higher education, academic teaching hospitals and medical centers, and research institutes affiliated with an institution of higher education. See “What Do I Need to Disclose” for details.

    • Do the new PHS regulations apply to all grants? Even fellowships?

    The PHS rules apply to all grants, except Phase I Small Business Innovative Research (SBIR) Small Business Technology Transfer (STTR) applications.  However, MSU’s policy does apply to these awards.

    • Do PHS requirements apply to any other funding sources?

    Yes, at this time the following health-related organizations that provide funding for research require the application of PHS standards:

    • Alliance for Lupus Research
    • Alpha-1 Foundation
    • American Asthma Foundation
    • American Cancer Society
    • American Heart Association
    • American Lung Association (ALA)
    • Arthritis Foundation
    • CurePSP
    • Juvenile Diabetes Research Foundation (JDRF)
    • Lupus Foundation of America (LFA)
    • Patient-Centered Outcomes Research Institute (PCORI)
    • Susan G. Komen Foundation

     

    This list is not exhaustive.  Please consult your sponsor if you are unsure whether they follow PHS FCOI regulations. 

     

    • Who is a PHS “investigator”? Is it only the Principal Investigator?

    No.  The term “Investigator” includes the project director (or Principal Investigator), key personnel, and any other person, regardless of title, who is responsible for the design, conduct, or reporting of research funded by PHS.  This may or may not apply to graduate students and post-doctoral fellows depending on how they meet the definition of “Investigator.”  See further information here.

    • If I have a collaborator at another institution in the United States or at a foreign institution, what do I have to do to ensure that I and MSU are in compliance with PHS regulations?

    If a PHS or NSF proposal includes involvement of entities outside of MSU (e.g. other Universities, businesses, etc.), the subrecipient entity and any investigator associated with the entity must also comply with PHS/NSF regulations regarding disclosure of conflict of interest.  If the subrecipient institution is in compliance, then associated individuals certify through their own institution.

    To ensure compliance, the MSU Principal Investigator must submit a Subrecipient Commitment form to the Office of Sponsored Programs completed by Subrecipient collaborator. On that form, the subrecipient either (a) certifies that the conflicts of interest policy of the subrecipient institution complies with PHS regulations or (b) states that the subrecipient investigators will be subject to MSU’s Policy and procedures. If the subrecipient will be subject to MSU’s Policy, they complete MSU's COI Training module (PHS only) and complete their disclosure using this form and this form to disclose entities. Please see the Forms tab.

    • Does MSU report any information to NIH/PHS?

    MSU is required to report Financial Conflicts of Interest annually to NIH/PHS.

  • Small Business Innovation Research (SBIR)/Small Technology Transfer Research (STTR)

    The Federal government created the SBIR/STTR programs. These programs were created to support scientific excellence and technological innovation through the investment of Federal research funds in critical American priorities to build a strong national economy (https://sbir.gov/about/about-sbir). Only small businesses are eligible to apply, however, MSU collaboration is required.

    • How can MSU faculty, staff, and students participate in SBIR and STTR awards when an MSU faculty member has a financial interest in the SBC?

    Research or fee-for-service work can be conducted under a subcontract from a small business in which a MSU employee or their immediate family member has equity or other financial interests if proper MSU approvals have been obtained.   Plans for proposed research to be conducted at MSU under an SBIR or STTR must be reviewed by the appropriate unit administrators and deans/separately reporting directors before the proposal may be forwarded to The Office of Sponsored Programs (OSP) via the Proposal Development (PD) document.  The unit administrators and deans/separately reporting directors should consider whether the proposal is a good use of MSU resources, will not compromise the faculty member’s MSU responsibilities, and reflects full cost recovery (direct and indirect) including faculty member’s time. OSP can assist MSU PIs with the subcontract proposal and award negotiation processes.

    If student participation is planned, the faculty member must obtain written permission by the Dean based on justification by Faculty Member and endorsement by his/her Chair to serve as the dissertation or thesis chairperson of any graduate committee for a student who is employed concurrently by the Small Business, funded by the Small Business or appointed or employed by MSU to carry out routine technical services for the Small Business.

    All participation in SBIR and STTR awards is subject to Agency Guidelines, Federal and State Law, as well as MSU Policies and Guidelines.

    • Can a company established by an MSU employee apply for an SBIR or STTR award if the employee is an interest holder in that company while working at MSU?

    Yes, if properly disclosed and managed under the auspices of the MSU FCOI Office. The PI for the company and the PI for an MSU subcontract may not be the same person. An MSU faculty member must request and obtain the written approval of his/her unit administrator and dean/separately reporting director before engaging in outside work for pay.

    • Can a full-time MSU employee serve as the PI for the small business applicant on an SBIR or STTR proposal?

    SBIR projects: Subject to Funding Agency Guidelines. At this time most Funding Agency Guidelines require the individual who serves as the Contact PI must be primarily employed at least 51% with the small business concern at the time of award and for the duration of the project period, unless a waiver is granted by the funding agency.  Co-Investigators need not meet this requirement. If the MSU employee serves as the small business concern’s Contact PI then the MSU employee would need to reduce their employment at MSU by 51%. Additionally, they would not be able to serve as the MSU subaward PI. 

    STTR projects: Subject to Funding Agency Guidelines.  The Contact PI, the first PI listed, must have a formal appointment with, or commitment to, the small business, which must be in the form of an official relationship between the parties, but need not include a salary or other form of remuneration.  If the Contact PI is not an employee of the Small Business, the applicant organization must officially affiliate the PI with the Small Business.  This can be done through a formal agreement with MSU and in the sponsoring agency's electronic system (e.g. NIH Commons).  If the MSU employee does serve as the small business concern's Contact PI then the MSU employee would need to reduce their employment at MSU accordingly (or have an employment agreement between MSU and the small business for the appropriate effort).  Additionally, the MSU employee would not be able to serve as the MSU subaward PI.  Please note that the 51% employment at the Small Business is not required for STTR grants.

    • Can an MSU postdoctoral scholar serve as the PI for the small business SBIR or STTR applicant?

    A postdoctoral scholar may prepare applications for funding through an organization other than MSU during non-duty periods.  The postdoctoral scholar must sever their appointment with MSU upon award.

    • Can the small business portion of the research be conducted at MSU?

    All participation in SBIR and STTR awards is subject to Agency Guidelines, Federal and State Law, as well as MSU Policies and Guidelines.

    SBIR Projects:  Normally, a minimum of two-thirds (67 percent) of the research or analytical effort must be carried out by the small business concern, not through a subcontract to the University.

    STTR Projects: The small business must perform a minimum of 40 percent of the work, and the single, collaborating research institution must perform a minimum of 30 percent of the effort. The remaining 30 percent may be attributed to either of these organizations or an additional third party.