Who should complete the Significant Financial Conflict of Interest form?
- All BSU full-time and part-time faculty involved in the design, conduct, and reporting of Federally funded research
- Any BSU employee (including students) who acts as a Research Investigator (Principal Investigator) on a Federally funded research project
- Any person involved in the design, conduct, and reporting of Federally funded research (this includes students and persons that meet the definition of Investigator, etc.)
- Any person serving on a research review committee (for ex. IRB, IACUC, etc.)
- Visiting faculty, scientists/scholars, consultants involved in any Federally funded research endeavor at BSU
- Any contractor, sub-contractor, sub-awardees, etc. who does not fall under the jurisdiction of Ball State University are expected to have, and comply with, their own policy on SFCI. If any of these parties do not have their own policy(s) on SFCI, then they must abide by the BSU policy concerning SFCI as a condition of working with, or receiving a contract from, BSU
When and how often do I need to submit a disclosure form?
Unless noted otherwise or required by an official entity, all SFCI/COI disclosures must be submitted within 30 calendar days of any of the following scenarios:
At least annually: the annual submission/renewal period begins September 1st
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 condition or specific term of a grant/award
As may be required by law
2. Event specific situations (events that may require a new SFCI 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 SFI (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?
New changes in significant financial conflict of interest legislation are in effect as of August 24, 2012. The university must comply with these federal changes 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 SFCI 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 significant 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 affect, or appear reasonably likely to affect, the manner or extent to which the employee carries out his or her University responsibilities. This includes an employee’s family.
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 common types of conflicts?
Significant 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.
How do I complete the Significant Conflict of Interest form?
All faculty and those graduate students working on research projects should complete the Significant Financial Conflict of Interest form.
The forms are reviewed by the Office of Research Integrity, as well as Department Chairs and Deans. You will be informed as to the status of your disclosure and if a management plan is necessary.
If you suspect you have a conflict that needs to be managed, please propose possible steps you could take to ameliorate the real or perceived conflict. Space for this is included on the forms. Your input is crucial for understanding how best to manage any real or perceived conflicts.
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. For more information on the CITI course, please see the Significant Financial Conflict of Interest, policies and forms tab of our website.
If I am a member of the public, how do I request information about Significant Financial Conflicts of Interest (SFCI) 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 significant financial interest disclosed to BSU that meet all of the following criteria:
- The significant financial interest was disclosed and is still held by the senior/key personnel associated with a PHS grant or contract; and
- BSU has determined that the significant financial interest is related to the PHS-funded research; and
- BSU has determined that the significant financial conflict of interest is a financial conflict of interest.
Requests for information concerning SFCIs 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:
Please note in the subject line: SFCI Request for Information; Attn. RCR Officer
In either situation, the request must, at a minimum, include:
- The name(s) of the senior or key personnel, and
- The title of the PHS-funded research project, and
- If possible, the PHS grant number.
The RCR Officer will respond within five (5) business days from receipt of the request.