The University is committed to transparency, integrity of scholarship, and independence as it pursues its mission to create, preserve, and disseminate knowledge through teaching, research, and community service. Accordingly, Grand Valley State University allows and encourages faculty and staff to engage in outside activities and relationships that enhance the mission of the University.

External sponsors, whether public or private, regularly institute conflict of interest disclosure requirements that the University must abide by in order to accept the funds and participate in the activity. The purpose of such requirements is to promote objectivity in research and to provide a reasonable expectation that the design, conduct, and reporting of sponsored activities will be free from bias arising from conflicting interests of participating personnel.

All GVSU personnel who meet the definition of “Investigator” on externally sponsored research applications, or serve as an “Investigator” on externally sponsored agreements, administered through the Center for Scholarly and Creative Excellence (CSCE) are required to submit a conflict of interest and commitment disclosure to the Office of Research Compliance and Integrity. An “Investigator” is defined as any person, regardless of title or position, who has independent responsibility for some aspect of the design, conduct, or reporting of the research, scholarly, or educational activity. Investigators include Principal Investigators, Co-Investigators, and all other individuals identified in the grant documents (e.g. application, budget, progress reports, etc.) submitted to the sponsor by GVSU, if the individual contributes to the development or execution of a project in a substantive, measurable way, whether or not they receive compensation.

The required disclosure by Investigators must be submitted prior to entering into an agreement or submitting a proposal for award to an external sponsor, and at least annually while the agreement/award is active. An annual disclosure is required even if no conflicts exist. An updated disclosure is also required within 30 days of any new conflict arising or an existing conflict ending or changing in a material way. The Office of Research Compliance and Integrity (ORCI) shall be responsible for reviewing the disclosures and, in conjunction with the Research Integrity Officer (RIO), developing and instituting an adequate mitigation plan for the management of any potential conflicts related to sponsored research and agreements administered by the CSCE. The RIO serves as the designated institutional official and has the final authority to approve and oversee mitigation plans.

GVSU personnel must also comply with the University’s Conflict of Interest Policy (SLT 10.1) and subsidiary policies, such as those in place with the Institutional Review Board (IRB) and the Institutional Animal Care and Use Committee (IACUC). Additionally, University personnel working on research funded by the Public Health Service (PHS) and/or other agencies that abide by PHS COI regulations, are subject to additional requirements in accordance with 42 C.F.R. Part 50.601 and 45 C.F.R. Part 94.5. Additional reporting requirements may be required under these other policies and regulations.

The table below provides references to the applicable procedures to follow based upon the type of research/sponsored activity submission.

For more information about conflicts of interest and commitment in research and sponsored activities, please visit the GVSU Conflicts of Interest and Commitment in Research & Sponsored Activities webpage or contact the ORCI at 616-331-3197 or [email protected].