Conflict of Interest

A conflict of interest is a situation in which the conduct of research/project is or appears to be compromised by a related outside financial or business interest on the part of the principal investigator (PI) or key research personnel. University faculty, staff, and administrators must disclose all financial and business relationships for assessment for a conflict of interests between their official University duties and outside financial or business interests or obligations.

NOTE: The National Science Foundation and Public Health Service (PHS) funding agencies require disclosure from all Principal Investigator(s) and Co-Investigator(s) for submissions to their agency and annual disclosure for all awards, even for proposals/projects without conflicts to disclose.

Step 1 Understand if a Conflict Exists

St. Cloud State University encourages and supports interactions of its faculty, staff and students with federal, state, and local governments, and with business and industry as important opportunities for education, research, and public service. Collaborations with external entities, can lead to perceived or real conflicts of interest (COI). COI arise when financial or other personal considerations have the potential to adversely affect, or have the appearance of adversely affecting, an employee’s professional judgment.

Conflicts of interest do not imply wrongdoing and the most effective way to ensure transparency and oversight of conflicts of interest is through disclosure, review, and management.

Most common types of COI include the conduct of research is or appears to be compromised by a related outside financial or business interest on the part of the principal investigator (PI) or key research personnel. Outside financial and business interests include remuneration or compensation from an entity other than the University and business relationships related to one’s responsibilities as a University employee.

Some examples:

• Salary or other payments received for services
• Equity interests, such as stocks, stock options or other ownership interests (excluding funds not directly managed by the employee)
• Income from intellectual property rights such as patents, copyrights and royalties except those received through the University
• Appointment to a position as an officer, director, agent or employee of a business entity
• Performing an official act as a University employee that directly benefits oneself or one’s spouse, domestic partner, or dependent children

Step 2 Complete Disclosure Process

Disclosure is the key to successfully managing conflicts of interest. The disclosure must be completed annually and updated within 30 days of discovering or acquiring a new potential conflict of interest.

NOTE: The National Science Foundation and Public Health Service (PHS) funding agencies require disclosure from all Principal Investigator(s) and Co-Investigator(s) for submissions to their agency and annual disclosure for all awards, even for proposals/projects without conflicts to disclose.

Step 3 Complete Conflict of Interest Training

Investigators with a conflict of interest on an externally funded grant or contract, and/or all new or existing investigators of PHS-funded research are required to complete conflict of interest training prior to engaging in the research and every four years thereafter. Training is also required when the institution finds an investigator not in compliance with the institution’s financial conflict of interest policy or management plan.

St. Cloud State University uses the Collaborative Institutional Training Initiative (CITI) to provide the online training component for various learner groups.

• New CITI User: Register
• Existing CITI User: Log In
  • Add the Conflicts of Interest course to your trainings
  • Select the appropriate learner group
  • Complete the required modules
  • Save a copy of your completion certificate

NOTE: There is no charge for taking this course if you are a current St. Cloud State student or employee and you register with your campus email.

Step 4 Reviewing and Managing Conflict

When a response to the conflict of interest disclosure reveals a potential, perceived or actual conflict of interest, a management plan is developed to document the oversight process and responsibilities. 

Management plans are created to proactively address questions that may arise regarding an individual's objectivity, integrity or professional commitment as a result of a disclosed activity, relationship or financial interest. Some federal funding agencies specifically require a management plan be reviewed and approved prior to the implementation of a project being funded.

The existence of a management plan demonstrates that the individual and the University have considered the situation carefully, recognize the potential issues involved, and have outlined the steps that will be taken to mitigate the situation. The management plan will be developed in coordination with the investigator’s supervisor and associated campus stakeholders.