Conflicts of Interest and Conflicts of Commitment

Conflicts of Interest

Conflict of Interest policies ensure that members of the university community do not engage in behaviors that risk compromising the university’s reputation and integrity.

Conflicts of interest especially may corrode the university’s reputation and, thereby, erode confidence in the university and diminish its trustworthiness and stature. Disclosure and management of these interests allows universities an opportunity to mitigate risk.

Conflicts of Commitment

Conflict of Commitment policies are intended to help employees manage and balance their primary obligations to the university with valuable outside professional activities that have the potential to benefit the employee and promote the mission of the university.

For more information:

File a Ball State University Conflict of Interest and Conflict of Commitment Form (PDF)

  • Note that for Part A, the amount should be $5,000.  

Click here to access our New Ball State Online Conflict Disclosure Form 

Click here to access the State of Indiana Disclosure Form 

Please contact Adam Kriska with any questions or difficulties accessing and using this. After submission the form will be routed to your supervisors for approval, then back to our office. If you have any questions completing this, please ask before submission to help streamline the process.  

  • Go to citiprogram.org
  • Click "Register"
  • There are seven registration steps. Select Ball State University as your "Organization Affiliation" Your username does not have to match your Ball State username and password. If you are earning CME/CEU credits by taking CITI Training be sure to check yes on Step 6.
  • The next page asks you to enter your institutional email address, department, and role in research. Required fields are marked with an asterisk.
  • Next you will “Select Curriculum.” You can return to this page at a later date to take additional courses.
    • For Question 1, choose “I do not need to take Human Subjects Research courses at this time.”
    • For Question 5, choose “Not at this time.”
    • For Question 6, choose “Yes.”
  • After selecting your curriculum, you will go to the Main Menu. To get started, look under "Status" and click on the red "Enter."
  • You will go to the "Required Modules" page. Start with the "Integrity Assurance Statement" and continue through the modules. You do not have to complete the modules in order. You must pass all modules with an overall score of 80%. You can complete module quizzes as many times as necessary. When all modules are passed, you may print your completion report through the link "Print" in the Learner's Menu.

As defined by the National Institute of Health, a financial conflict of interest (FCOI) occurs if:

“With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.  For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary…"

As of 2012, there have been changes to the Financial Conflict of Interest (FCOI) policy, and all faculty or students engaged in federally funded research are required to submit a FCOI Disclosure Form.

Researchers are encouraged to review the Ball State University Financial Conflict of Interest policy before filling out the form. Please be aware that aspects of this policy may change to meet institutional needs and conformity with federal and state guidance.

For More Information

If you have any questions about the Financial Conflict of Interest form or the Financial Conflict of Interest policy, please contact the Office of Research Integrity at 765-285-5052 or View Email.

When and how often do I need to submit a disclosure form?

Unless noted otherwise or required by an official entity, all FCOI/COI disclosures must be submitted within 30 calendar days of any of the following scenarios:

General

  • At least annually, from the date of initial submission.
  • When a new appointment begins and/or when a new faculty member starts working at BSU on a Federally funded research project.
  • When required by a Federal agency.
  • When required as a term or condition of a grant/award.
    • For PHS/NIH grants- thirty (30) calendar days prior to the submission of PHS/NIH grant application being submitted, thirty (30) calendar days of the annual renewal date, and when there is a change in circumstances.
    • For NSF grants- disclosure must be made at the time of proposal and be updated annually, or whenever new reportable interests are obtained. Each disclosure must be reviewed before funds may be spent.
  • As may be required by law.

Event-specific situations

The following types of events that may require a new FCOI disclosure and/or amendment of the current disclosure:

  • When the situation creating the conflict changes (a material change).
  • When service on a research review committee begins: if one is not already on file, then this must be filed within 15 calendar days.
  • When discovering a new or previously unreported FCOI (must be filed within 15 calendar days).
  • When a new situation comes up that creates an actual or perceived conflict (a material change) different from one previously disclosed.
  • When awarded a PHS or other Federally funded research grant and before any of those funds are expended.

Why do I need to fill this form out?

The university must comply with federal disclosure guidelines to ensure we are able to receive federally funded research grants and compliance with other federal and state legislation. Through having all faculty, staff, and graduate students involved in research projects complete the FCOI form annually, Ball State will be in compliance with this legislation.

Why is Office of Research Integrity handling this issue?

The new changes in federal legislation impact federal research dollars and state grants for various programs and improvements. The Office of Research Integrity needs to ensure that Ball State researchers comply with federal and state regulations on conflict of interest/conflict of commitment.

What is a financial conflict of interest?

Financial interest or anything of monetary value that reasonably appears to be related to the employee’s Institutional Responsibilities including but not limited to:

  • Equity interests in a publicly traded company or business that exceeds $5,000.
  • Equity interest includes any stock, stock option, or other ownership interest.
  • Intellectual property rights (e.g., patents, copyrights and royalties from such rights).
  • Remuneration, including salary, consulting fees, honoraria, paid authorship, travel reimbursement, etc., received from a publicly traded company during the twelve-month period preceding the date on which an employee is making a disclosure, and/or an Equity Interest held in such publicly traded company, if the aggregate value of such remuneration, plus the value of the equity interest as of the date of disclosure, exceeds $5,000.
  • Remuneration, including salary, consulting fees, honoraria, paid authorship, travel reimbursement, etc., received from a non-publicly traded company during the twelve-month period preceding the date on which an employee is making a disclosure, if the remuneration exceeds $5,000.
  • Any Equity Interest in a non-publicly traded company or business, regardless of value.

The term does not include:

  • Salary, royalties or other remuneration from the University.
  • Income from seminars, lectures or teaching engagements sponsored by a federal, state, or local government agency or an Institution of higher education.
  • Income from service on advisory committees or review panels for public or nonprofit entities.
  • Income from service on panels for a federal, state or local government agency or institution of higher education (includes an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education).
  • Intellectual Property Rights assigned to the Institution and agreements to share in royalties related to such rights.
  • Any financial interest arising solely by means of investment in a mutual, pension, or other institutional investment fund over the management and investments of which the employee does not exercise control.

*Note that this definition of "significant financial interest" differs from the definition of "pecuniary interest" under the Indiana Conflicts of Interest Law.

What is a conflict of commitment?

When a University employee's activities outside of the University, whether domestic or foreign, affect--or appear reasonably likely to affect--the manner or extent to which the employee carries out responsibilities to the University.

Does disclosure mean I have to stop my activities?

Not necessarily. The purpose of disclosure is to develop appropriate management plans. Ball State University is a great place for students, faculty, and staff to work and learn. Our goal is to ensure all Ball State employees keep their Ball State University professional life as separate as they can from outside activities. For example, if you have a separate business or source of income, please keep this business and source of income separate from your university activities. Management plans can identify steps to separate your activities, not necessarily stop them. Remember, conflicts of interest/conflicts of commitment can be both real and perceived. The management plan addresses both real and perceived conflicts.

What are some examples of common types of conflicts?

financial conflicts of interest (federal)

You own $8,500 is stock at Acme Pharma Corporation, and have just received a grant from this corporation to conduct cutting edge research in your field.

Conflict of Commitment (BSU Policy)

You are a full-time professor at Ball State University; however, you also own a private consulting firm which also occupies your time an additional 40 hours a week.

What is the purpose of the NIH SFCI training?

The NIH training provides an overview of significant financial conflicts of interest. After the training, you will be better informed of the various policies that apply to faculty, staff, and some students. This training is REQUIRED for any projects that are funded by the Public Health Service, and it's affiliated agencies (NIH, CDC, etc.).

BSU also uses CITI as one of the training options for meeting the NIH training requirement. Review the Training section below to learn more.

If I am a member of the public, how do I request information about Financial Conflicts of Interest (FCOI) disclosed to BSU?

Public Health Service (PHS) regulations require that Ball State University (BSU) respond in writing, within five (5) business days, to any request for information concerning any financial interest disclosed to BSU that meet all of the following criteria:

  1. The financial interest was disclosed and is still held by the senior/key personnel associated with a PHS grant or contract; and
  2. BSU has determined that the financial interest is related to the PHS-funded research; and
  3. BSU has determined that the financial conflict of interest is a financial conflict of interest.

Requests for information concerning FCOIs related to PHS grants and contracts awarded to BSU must be addressed to BSU’s Responsible Conduct of Research (RCR) Officer and sent by US Mail to the following address:

Ball State University
2000 University Ave.
Office of Research Integrity, WQ 100
ATTN: RCR Officer
Muncie, IN 47306

Or emailed to:
View Email
Please note in the subject line: “FCOI Request for Information; Attn. RCR Officer”

In either situation, the request must, at a minimum, include:

  1. The name(s) of the senior or key personnel, and
  2. The title of the PHS-funded research project, and
  3. If possible, the PHS grant number.

The RCR Officer will respond within five (5) business days from receipt of the request.

For those researchers applying for PHS/NIH funding, please make sure you take the required SFCI training course prior to engaging in any PHS/NIH funded research.

This training is also required every four (4) years afterwards. BSU currently uses the Collaborative Institutional Training Institute (CITI) Conflicts of Interest Course. This course can be found:

  • CITI Conflict of Interest Course
  • After you log in, click on “Add a Course”
  • When you get to the “Select Curriculum” page, select “yes” on Question 5.
  • Then take the course.
  • CITI will send out reminder emails when you near the end of the four (4) years.

You may also take the NIH SFCI training found here:

  • NIH Financial Conflict of Interest Tutorial
  • If you take this course (or are requested to by NIH) please be advised that you will need to remember when you need to retake the course in four (4) years’ time.
  • Once completed, please send a copy of your completion to View Email and address it to the RCR Officer. You may also need to supply a copy to the grant manager you are working with. Please check with your grant manager if this is needed.

Frequently asked Questions

This is a proactive measure to maintain the public’s trust, and to protect our employees. Without these disclosures, employees may not always know what state and federal laws apply to their activities. Disclosure makes activities transparent. This will also help maintain the integrity of the research we all do at Ball State University.

  • A conflict of interest is NOT a sign that there are ethical issues. Conflicts of interest inform the university and the departments what needs to be done, so that there do not become and ethical issues due to any potential or perceived conflicts.
  • Conflicts can be individual or institutional
  • They can involve
    • Financial incentives in research
    • Business Ownership
    • Consulting
    • Outside Employment
    • Commitments to external organizations

In our case, this is going to refer to the completion and submission of our COI form. This will mainly consist of information from you and your immediate families financial interests and time commitments.

University employees
  • Any income/interest that is more than $5,000, combined with your spouse and dependent children
  • Anything of monetary value from a foreign entity
  • Review the policy carefully to see if any exceptions to the policy may apply in your case

 

  • When you discover an issue that isn’t previously reported, promptly report it. Otherwise, reporting should happen proactively and before any activities have happened.
  • If you have already filed a disclosure, this must be done annually.

You can contact our office directly and discuss your questions with us. You will not be required to disclose any personal identification or identifying information. 

  • Activities of the employee which advance the employee’s financial, professional, or other interests, or those of a dependent, to the detriment of the University.
  • Holding an academic or research appointment by a full-time faculty member at (any) another educational institution, including teaching through the Internet or through the use of other modalities.
  • Utilizing University students, employees, facilities or materials in the pursuit of outside activities from which the University will derive no benefit.
  • Engaging in research or consulting activities that interfere or compromise the employee’s execution of responsibilities to the University.
  • Deriving any direct or indirect financial benefit, including royalties, from any University action.

Yes, please contact Adam Kriska to set up a training session.

Email: akriska@bsu.edu

Phone: 765-285-6510