Conflicts of Interest and Commitment in Research & Sponsored Activities
The University is committed to basic values of transparency, integrity of scholarship, and independence as it pursues its mission to create, preserve, and disseminate knowledge through teaching, research, and public 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. All faculty and staff members are to act with honesty, integrity, and in the best interest of the University when performing their duties, and to abide by the highest standards of research, educational, professional, and fiscal conduct.
Given that Grand Valley State University allows and encourages outside activities and relationships that enhance the mission of the University, potential conflicts of interest (COIs) and commitment (COCs) are inevitable. Outside activities should not, however, interfere with an individual’s University obligations. Faculty and staff must not use their official University positions or influence to further gain or advancement for themselves, parents, siblings, spouse or partner, children, dependent relatives, or other personal associates, at the expense of the University.
All actual and potential conflicts of interest or commitment must be disclosed to a designated University official; evaluated; and, if found to be significant, eliminated or managed. Academic or administrative units may require further disclosure and conflict management than mandated by this policy as may be deemed appropriate by the unit and its supervising administrator. For more information, read our Conflict of Interest in Research Policy.
Note that the Conflict of Interest in Research Policy is separate from other COI policies established by the Board of Trustees and the Senior Leadership Team. GVSU personnel are responsible for abiding by all COI policies, which can be found on the University Policies page.
COI/COC Disclosure Process
The disclosure process for reporting conflicts of interest and commitment is dependent upon the type of submission. Please consult the table below to determine if you need to submit a disclosure and the process to be used.
|
Submission Type |
Who Submits? |
Where to Submit? |
Procedures |
Responsible Office/Committee |
|---|---|---|---|---|
|
External funding applications/agreements administered by the Office of Sponsored Programs (OSP) and the Technology Commercialization Office (TCO) (Includes: sponsored program submissions, service agreements, testing agreements, material transfer agreements, data use agreements, research collaboration agreements, educational affiliation agreements, non-disclosure agreements) |
Investigator*
|
Conflicts of Interest and Commitment Disclosure Form Form is housed in OneAegis--GVSU username and password login required. |
Office of Research Compliance and Integrity |
|
|
Institutional Review Board (IRB) Protocol |
Principal Investigator, on behalf of project team |
In the IRB Submission Form |
Institutional Review Board |
|
|
Institutional Animal Care and Use Committee (IACUC) Protocol |
Principal Investigator, on behalf of project team |
In the IACUC Submission Form |
IACUC Policy 3.30: IACUC Protocol Personnel Conflict of Interest |
Institutional Animal Care and Use Committee |
*Investigator: Any person, regardless of title or position, who has independent responsibility for some aspect of the design, conduct, or reporting of research, scholarly, or educational activity. Investigators include Principal Investigators, Co-Investigators, and all other individuals identified in the grant application, grant budget, progress report, or any other report 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 request compensation. All Investigators on externally-sponsored funding applications and agreements administered by the OSP/TCO are required to submit a COI/COC disclosure, and every external funding application and agreement must have at least one Investigator identified in the submission materials.
Who Is Required to Submit a COI/COC Disclosure Form?**
|
Title/Role |
Require COI/COC Disclosure Form? |
Guidance |
|---|---|---|
|
Principal Investigator (PI) or Project Director |
Always |
|
|
Co-Investigator/Co-PI |
Always |
|
|
Project Managers/Project Coordinators |
Rarely |
Project managers and coordinators typically operate under the direction of the PI and do not have independent responsibility for any design, conduct, or reporting of the activity. |
|
Laboratory Managers/Technicians |
Rarely |
Laboratory managers and technicians typically operate under the direction of the PI and do not have independent responsibility for any design, conduct, or reporting of the activity. |
|
Graduate/Postdoctoral Fellows paid on fellowships |
Always |
This includes Graduate Fellows on Michigan Space Grant Consortium submissions |
|
Graduate/Postdoctoral Fellows paid on training grants |
Never |
|
|
Faculty Sponsor for Graduate/ Postdoctoral Fellows |
Always |
|
|
Postdoctoral Fellows paid on research grants |
Rarely |
Postdoctoral Fellows (Postdoctoral Research Associates, Postdoctoral Research Fellows, Postdoctoral Fellows, etc.) are typically considered in training and conduct research under the guidance and mentorship of a PI and do not meet the criteria necessary to be categorized as Investigators. Note that Postdoctoral Fellows paid on fellowships and training grants are considered separately above. |
|
Graduate Students |
Rarely |
Graduate students are typically considered in training and conduct research under the guidance and mentorship of a PI. Note that Graduate Fellows paid on fellowships and training grants are considered separately above. |
|
Undergraduate Students |
Rarely |
Undergraduate students are typically considered in training and conduct research under the guidance and mentorship of a PI. |
|
Other Significant Contributors (OSC) |
Never |
These individuals are typically included with "Effort of zero person months” or “as needed.” Per NIH, these are not acceptable levels of involvement for those designated as Key Personnel. |
|
Program Evaluators |
Never |
|
|
Consultants |
Rarely |
Consultants are individuals who generally provide a ‘fee for service’ and do not typically conduct research. They may provide insight and expertise to the PI but independently are not responsible for the design, conduct or reporting of research. In most cases, they do not meet the criteria of Investigator. |
|
Collaborators (unpaid) |
Never |
Unpaid collaborators do not contribute measurable effort, and therefore do not meet the criteria of Investigator. They should be included as OSCs. |
|
Collaborators (paid) at GVSU |
Rarely |
Most paid collaborators at GVSU will generally not meet the criteria of Investigator. However, Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) PIs are considered collaborators while also meeting the criteria of Investigator, and therefore require COI/COC disclosure. |
|
Collaborators (paid) at another institution, including subrecipient PIs and senior/key personnel |
Sometimes |
Paid collaborators at another institution should be included in the proposal as a subrecipient. Disclosure to GVSU is only required when collaborating entities have agreed to follow GVSU’s COI/COC policy as a condition of the subrecipient agreement. |
**This table is to be used as guidance to help determine who is considered an "Investigator" on externally funded applications and agreements. Whether an individual is ultimately considered an “Investigator” is dependent upon the sponsor’s requirements and the individual’s role in the project. Final determination regarding an individual’s classification as an Investigator (and therefore requirement to complete a Conflicts of Interest and Commitment Disclosure Form) is determined by the office to which the application was submitted (i.e., OSP or TCO).
COI/COC Review and Mitigation
COI/COC disclosures are initially reviewed by Office of Research Compliance and Integrity (ORCI) staff. If additional review is required, the review is referred to the University's Research Integrity Officer (RIO). Final disposition for every project on which an Investigator has disclosed a potential conflict of interest or commitment must be either 'No Conflict' or 'Conflict Managed.' If a mitigation plan is needed to address the conflict, the ORCI will coordinate the details of the plan with the Investigator and the RIO.
COI Training
Conflict of Interest training is available through CITI. Note that this training is required for GVSU researchers on Public Health Service (PHS)-funded awards and National Science Foundation (NSF) awards, and must be renewed every 4 years. Click here to learn more about CITI.
Whom Can I Contact with Questions?
Benjamin Vesper, Ph.D., M.B.A., PMP, CIP®, CPIA®, ECoP® (EAR/ITAR): Director, Office of Research Compliance and Integrity
Office Address: 049 James H. Zumberge Hall
Email: [email protected]
Phone: (616) 331-9137
Kaitlyn Daza, Ph.D., ECoP® (EAR/ITAR): Research Compliance Specialist, Office of Research Compliance and Integrity
Office Address: 049 James H. Zumberge Hall
Email: [email protected]
Phone: (616) 331-9438
Robert Smart, Ph.D.: Authorizing Institutional Official, Vice Provost for Research Administration, Executive Director, Center for Scholarly and Creative Excellence
Office Address: 049 James H. Zumberge Hall
Email: [email protected]
Phone: (616) 331-2281