POLICY NUMBER: 414
POLICY NAME: Conflict of Interest and Conflict of Commitment Identification and Disclosure
| Effective Date: | October 1, 2025 |
| Last Review Date: | June 13, 2025 |
| Next Scheduled Review Date: | June 2030 |
MSU is committed to advancing knowledge and transforming lives through education, research, outreach, engagement, and economic activities. As a public institution of higher learning, MSU is also committed to pursuing innovation and partnerships with the communities that we serve to improve the State of Michigan and the world.
MSU encourages and permits participation in Outside Activities (as defined in this policy) and relationships that enhance and are consistent with its mission. Outside Activities support MSU’s mission and MSU’s contributions to the boarder community through collaboration and partnership. However, Outside Activities have the potential to create a potential or actual Conflict of Interest (COI) or Conflict of Commitment (COC). One of MSU’s values is to be “committed to the highest ethical and academic standards. As a public institution we are committed to transparent decision making and accountable governance.”1 To that end, MSU Covered Individuals and Investigators have a duty to act in the best interest of the University and to maintain high ethical and professional standards including acting with honesty, transparency, and integrity when performing their Institutional Responsibilities. This duty also includes abiding by high standards of research, educational, professional, and fiscal conduct.
Covered Individuals and Investigators must ensure that their relationships with outside Entities are transparent, grounded in objectivity, and do not improperly influence or interfere with their professional judgment and Institutional Responsibilities. Covered Individuals and Investigators must disclose Outside Activities, as set forth in this policy, to the University for evaluation and approval. Should any actual or potential Conflicts of Interest (COI) or Conflicts of Commitment (COC) exist, they must be managed or eliminated as described in Section V. Covered Individuals and Investigators must also disclose Outside Activities to avoid Financial Conflicts of Interest (FCOI) in research or these conflicts must be managed as described in Section IV (b) and the FCOI Standard Operating Procedure (FCOI SOP).
The purpose of this policy is to provide expectations, requirements, and parameters for the identification, disclosure, and approval (where applicable) of relationships between Covered Individuals, Investigators, outside Entities, and University matters. This policy shall not be interpreted or enforced in a way that infringes upon a faculty member's academic freedom. See Faculty Rights and Responsibilities policy.
This policy is in compliance with the following:
1 MSU Strategic Plan, Values Statement
This Policy applies to all Covered Individuals and Investigators, unless otherwise noted. If any portion of this Policy conflicts with another written MSU policy or guidance related to Conflicts of Interest, the terms of this Policy will prevail, though additional criteria and restrictions may be applied through other policies (e.g., administrative, college, department level) and may require further disclosure and conflict management.
Academic Administrators: All positions identified as Academic Administrators in the Academic Hiring Manual.
Conflict of Commitment (COC): A potential conflict of commitment happens when a Covered Individual or Investigator’s external relationships or Outside Activities can possibly interfere or compete with the University’s educational, research, or service missions, or with that individual’s time and effort to fulfill University expectations, obligations, and/or willingness to perform the full range of responsibilities associated with their University position. Conflict of Commitment can also include obligations to improperly share information with an Entity outside of the University or obligations to withhold information from the University or research agency.
Conflict of Interest (COI): A potential conflict of interest happens when an individual’s outside relationships or activities outside of the University affect, appear to affect, or have the potential to affect their professional judgment or obligations and responsibilities to the University. See FAQs for examples of potential conflicts of interest.
Covered Individuals: Faculty, Executive Management, and Academic Administrators.
Duty Period: The duty period for Covered Individuals on an academic year (AY) appointment is the nine-month period running from August 16th through May 15th of the following calendar year. If a Covered Individual on an AY appointment receives a summer assignment, the duration of the summer assignment is also part of the duty period. The duty period for Covered Individuals on an annual year (AN) appointment is the full-year assignment of duties and responsibilities (or any period specified in the relevant appointment letter).
Entity: Any business, company, or other organization, whether public or private, including but not limited to any partnership, corporation, limited liability corporation, unincorporated association, or other institution or organization, whether for-profit or not-for-profit.
Executive Management: All positions identified as Executive Management in the Executive Management Position Titles.
Faculty: All positions identified as Ranked Faculty in the Academic Hiring Manual University Approved Positions/Ranks.
Financial Interest: Any monetary or equity interest held by a Covered Individual or Investigator or their Immediate Family Member that could create an actual or potential COI. Financial interests include, but are not limited to, compensation such as income, consulting fees, honoraria, royalties, an interest in a business consisting of stocks, stock options, private equity or other similar ownership interest (excluding any interest arising solely from a pension, mutual fund, or other investment fund in which the Covered Individual or Investigator does not exercise control), or any other form of compensation from an Entity.
Financial Conflict of Interest (FCOI) in Research: A Significant Financial Interest that could directly and significantly affect the design, conduct, or reporting of the funded research, or present the appearance thereof.
Immediate Family Member: A Covered Individual or Investigator’s spouse, domestic partner, and dependent children and stepchildren.
Institutional Responsibilities: Professional responsibilities conducted on the University’s behalf, which include, but are not limited to, educational, research, scholarship, outreach, service, healthcare, and administration activities, in the general area of expertise for which the Covered Individual or Investigator is employed by the University.
Investigator: The Project Director or Principal Investigator and any other person responsible for the design, conduct, or reporting of research, regardless of title or position, or if identified in the federal award as a Covered Individual.
Outside Activities: Any paid or unpaid activity, both domestic and non-domestic, related, or similar to a Covered Individual or Investigator’s Institutional Responsibilities, which is performed outside of the University and beyond the scope of their employment responsibilities. Examples include outside consulting, employment, creation of a startup company, participation in a foreign government sponsored talent recruitment program, conducting research outside of MSU that is not subject to approval by the Office of Sponsored Programs or Business Connect, teaching at another educational organization or entity outside of the University. See specific College website for further examples of Outside Activities.
Remuneration: Salary and any payment for services not otherwise identified as salary, including, but not limited to, consulting fees, honoraria, and paid authorship.
Scholarly Activities: Activities which extend an employee’s Institutional Responsibilities of teaching, research, and service to other institutions, organizations, and professional societies. These are activities that are expected of employees as part of their professional service and do not require prior approval, however these activities may need to be reported in MSU grant applications, progress reports, or the MSU COI disclosure. Examples include peer review of articles and grant proposals, presentations at professional meetings, leadership positions in professional societies, service on advisory committees for U.S. government funding agencies, non- profit foundations or educational organizations, musical or creative performances. See specific College website for further examples of Scholarly Activities.
Significant Financial Interest (SFI) (for Investigators): For researchers and as defined in 42 C.F.R. § 50.603, a SFI includes an external financial interest consisting of one or more of the following interests of an Investigator (and those of the Investigator's Immediate Family Members) that reasonably appears to be related to their Institutional Responsibilities during the 12 months preceding disclosure, and includes the following:
The term SFI does not include the following:
2 Qualifying institutions of higher education are institutions within the United States, among other requirements as defined in 20 U.S.C. 1001.
MSU recognizes that participation of Covered Individuals in Outside Activities are necessary in supporting its mission, however at times these relationships can create Conflicts of Interest (COIs). Outside Activities are permitted and encouraged, as long as these activities receive approval as outlined in this Policy and the activities are disclosed in compliance with this Policy and federal and state rules and requirements. Furthermore, Covered Individuals or Investigators must not use their official position or influence to further their personal gain or advancement or that of an Immediate Family Member at the expense of the University or against University policy. The University will not accept or enter into agreements, contracts, gifts, or purchases that give rise to a COI unless the conflict can be eliminated or appropriately managed (e.g., with a University conflict management plan).
Covered Individuals or Investigators must pursue their research, teaching, outreach, and service responsibilities with integrity and proper professional judgment in a manner consistent with the highest standards of their respective disciplines and in the best interests of the University. A Covered Individual or Investigator’s reputation for integrity and for exercising proper professional judgment can be seriously compromised, however, if the Covered Individual or Investigator fails to disclose a Significant Financial Interest or Outside Activity that needs management. Moreover, a Covered Individual or Investigator’s unmanaged and unresolved COI can undermine confidence in the University and, thus, harm its standing and that of its entire faculty.
Separate individual University policies, as listed in Section X Related Policies, Information, and Attachments below, also include COI and COC related guidance and have oversight of other specific COI concerns, such as COI in intellectual property, gifts, purchasing, and other specific circumstances. Furthermore, the University will comply with all federal and state rules, requirements, policies, COI statutes, regulations, and guidance as applicable.
Due to the innovative pursuits of MSU Covered Individuals and Investigators who participate in research, MSU must identify and manage conflicts of interest and the appearance of conflicts of interest that may compromise or bias objectivity or judgement relative to research. In most cases, conflicts or potential conflicts can be appropriately managed, instead of removed, thereby enabling Covered Individuals and Investigators participating in MSU research to engage objectively and with integrity, while having a financial interest in an Entity that is manageable. In order to do so, the disclosure of Outside Activities and Significant Financial Interests are imperative to protect Covered Individuals, Investigators, and MSU, so any Conflicts of Interests and Financial Conflicts of Interests are properly managed. The Public Health Service (PHS), National Science Foundation (NSF), Department of Energy (DOE), and other federal agencies have developed policies and procedures to ensure that the design, conduct, and reporting of research funded under research grants and contracts will not be biased by conflicts of interest affecting the Investigators responsible for such research.
Investigators conducting MSU research must disclose their Outside Activities and Significant Financial Interests, as defined in this policy and 42 C.F.R. § 50.603 to avoid potential conflicts of interest or allow any conflicts to be managed as described in the FCOI SOP.
A FCOI may be present when an Investigator or their Immediate Family Member has a Significant Financial Interest that is related to the research. Examples include, but are not limited to a SFI that could affect the design, conduct, or reporting of the research, or the SFI is held in an entity that is funding the research. Further information about the review and management of FCOIs is included in the FCOI SOP.
To the extent that any legal requirements are more stringent than this policy, they will take precedence.
University employees are encouraged to engage in Outside Activities when their activities reinforce the mission of the University and do not compete with the University. At the same time, MSU’s expectation is that the primary professional skills, expertise, and work effort of its employees are committed to MSU. This section is intended to protect the integrity of the Employee-University professional relationship, MSU’s responsibility to the public, and to provide that Covered Individuals and Investigators remain accessible to students, colleagues, administrators, and the public and do not create conflicts that cannot be managed.
The University recognizes that, through consulting and other Outside Activities, including relationships with government, industry, non-profit organizations, and other Entities outside the University, its employees can make valuable contributions off campus while enhancing their expertise in their discipline. Covered Individuals and Investigators may engage in Outside Activities, provided that these activities do not constitute a Conflict of Commitment and/or a Conflict of Interest and comply with all other applicable university policies. A Conflict of Commitment occurs when the time and attention a Covered Individual or Investigator devotes to Outside Activities interferes with the performance of the Covered Individual or Investigator’s Institutional Responsibilities to MSU. A Conflict of Interest may occur as described in Section IV(b) Financial Conflict of Interest (FCOI) in Research, or for example, a potential relationship that is in conflict with MSU’s Patent Policy, Copyright Policy, or other MSU policies listed in Section X Related Policies, Information, and Attachments.
To ensure that Outside Activities do not conflict with a Covered Individual or Investigator’s Institutional Responsibilities, such activities must be disclosed in the Outside Activity Approval Form and receive approval from the dean or head of the major administrative unit. Activities that are defined as Scholarly Activities do not require prior approval however these activities may need to be reported in MSU grant applications, progress reports, or the MSU COI disclosure.
A Covered Individual may engage in Outside Activities up to an average of four (4) days a month during their Duty Period. The totality of all approved Outside Activities and overload pay assignments for the Covered Individual may not exceed a total average of four (4) days a month. A “day” for purposes of the four day per month limit is equivalent to a standard workday (e.g. 8 hour day) of the Covered Individual.
This time limit does not apply to the activities undertaken under a Covered Individual’s approved dual appointment, when the Covered Individual is on an unpaid leave of absence. These activities must be in compliance with MSU’s Dual Appointment Policy.
Covered Individuals with an appointment of at least fifty percent (50%) but less than one hundred percent (100%) are allowed a prorated number of days for Outside Activities, proportional to the four (4) day average. Covered Individuals with an appointment of less than fifty percent (50%) are not allowed to engage in Outside Activities during their designated work time for MSU.
A Covered Individuals and Investigators may request approval to engage in Outside Activities if all of the following conditions exist:
The Outside Activity will not adversely affect the University’s interests or violate University policies or regulations, including, but not limited to, policies or regulations related to intellectual property, use of the University's name, logo, letterhead, or other resources (See Section V (10), Use of University Resources), etc.
Each dean/head of the major administrative unit shall keep Outside Activity Approval Forms submitted by Covered Individuals and Investigators on file for at least three years.
Additionally, each dean/head of the major administrative unit shall submit annual reports to the Office of the Provost concerning the Outside Activities performed by Covered Individuals and Investigators in that college/administrative unit.
Covered Individuals or Investigators who hold academic year appointments or part-time appointments of at least 50% time may engage in Outside Activities during Non-Duty Periods. MSU recognizes that Covered Individuals may engage in external employment, including teaching and research opportunities, particularly during the summer months. The university values the professional growth and contributions faculty make beyond their institutional roles and understands that such engagements are an important part of their academic and professional pursuits.
To ensure alignment with university policies, Covered Individuals are expected to submit an Outside Activity Approval Form for any external employment or professional commitments.
This process allows the university to assess potential Conflicts of Commitment or Conflicts of Interest, such as compliance with intellectual property (IP) policies. Outside Activities during Non-Duty Periods are not subject to time limitations; however, to ensure a Conflict of Commitment does not exist, Outside Activities must be disclosed in the Outside Activity Approval Form and receive approval from the dean or head of the major administrative unit. This reporting process is not intended to limit faculty opportunities but rather to provide clarity and assurance that external engagements are conducted in a way that upholds institutional commitments while respecting a Covered Individual’s ability to pursue outside work.
Faculty with a 0.50 FTE or more appointment in the College of Human Medicine or Osteopathic Medicine (excluding Physician Assistant Medicine) may engage in Outside Activities that include patient care or that include administrative or consulting activities significantly related to, but not directly involved in, patient care under the following conditions:
Faculty Members with a 0.50 FTE or more appointment in the College of Nursing or Physician Assistant Medicine in the College of Osteopathic Medicine may engage in Outside Activities that include patient care or that include administrative, or consulting activities significantly related to, but not directly involved in, patient care under the following conditions:
Faculty in the College of Veterinary Medicine may engage in Outside Activities pursuant to this policy, provided that private practice by Faculty in the College of Veterinary Medicine may occur only in accordance with College of Veterinary Medicine policy, and provided further that, if a practice plan is established for the College of Veterinary Medicine in the future, any income derived by Faculty of the College of Veterinary Medicine from private practice will be subject to the provisions of that practice plan.
The University’s policies regarding intellectual property are applicable to Covered Individuals engaging in Outside Activities. If a Covered Individual seeks to use existing intellectual property owned by the University in Outside Activities, the unit administrator consulting with the Covered Individual, must consult with MSU Technologies before the Outside Activity may be approved or performed. The purposes of this consultation are to avoid violation of third-party licenses, to prevent loss of University patent rights, and to preserve the rights of other authors or inventors.
Decisions about whether to involve students and staff in a Covered Individual’s Outside Activities should be guided by determining whether the proposed activities best serve the interests of the students and staff. Covered Individuals cannot require students or staff to become involved in a Covered Individual’s Outside Activities. Covered Individuals are continually called upon to judge the quality of work of students and staff. Thus, a Covered Individual typically should not involve students and staff in the Covered Individual’s Outside Activities; such involvement may impact the Covered Individual’s judgment of students and staff.
If in the best interest of students or staff, Covered Individuals may hire students or staff to assist with their Outside Activities and if they have received appropriate approval. Such arrangements must be fully disclosed and receive prior approval from: 1) the Covered Individual’s department or unit head, 2) the student's faculty advisor or the dean of undergraduate or graduate education, 3) the Department of the Office for International Students and Scholars (if the student or staff is on a visa), and/or 4) the staff member’s direct supervisor.
Safeguards must be put in place on a case-by-case basis to ensure that University duties and the institution’s academic mission are not compromised. The involvement of University students or staff (especially those for whom the Covered Individual has oversight responsibilities) may require ongoing monitoring. Covered Individuals should avoid any situation that could be perceived as directing students or staff to participate in research or Outside Activities that primarily serve personal interests.
Covered Individuals may use University facilities, supplies and materials, equipment, services, or employees for Outside Activities, but only if:
3Covered Individual using University facilities, supplies and materials, services, or equipment for Outside Activities do not need to reimburse the University for the fair market value of the use if it is a de minimis, incidental use which imposes no, or little, additional cost or expense on the University. However, use of equipment for Outside Activities must not conflict with the use of the equipment for MSU activities (e.g., research, internal, or office, etc.).
Approval of Outside Activities is subject to termination at any time. Written reasons for the decision to terminate approval will be provided to the Covered Individual or Investigator by the Covered Individual or Investigator’s unit administrator. Decisions to terminate approval for Outside Activities are not disciplinary actions. A Covered Individual or Investigator who wishes to challenge a decision terminating an Outside Activity through the Faculty Grievance Policy may only do so if the termination is contrary to University, college, department, school, or unit policy or established practice.
When involvement in an Outside Activity substantially interferes with a Covered Individual’s or Investigator’s performance of their Institutional Responsibilities, the Covered Individual or Investigator’s unit administrator may issue an administrative warning to the Covered Individual or Investigator or their unit administrator may arrange by mutual agreement a voluntary unpaid leave of absence or a reduction in the individual’s appointment. Voluntary leaves of absence should normally not exceed one year as stated in the MSU Leave Policies, and the frequency and duration of leaves of absence should not impair a Covered Individual or Investigator’s contributions to the University.
In compliance with the CHIPS and Science Act of 2022, MSU must maintain a policy that prohibits Covered Individuals and Investigators4 from participating in a Malign Foreign Talent Recruitment Program. See MSU’s Policy on the Prohibition of Participation in Malign Foreign Talent Recruitment Programs5.
4As defined in the MSU Policy, Prohibition of Participation in Malign Foreign Talent Recruitment Programs.
5As defined in the MSU Policy, Prohibition of Participation in Malign Foreign Talent Recruitment Programs.
Certain Covered Individuals and Investigators must annually and before submitting an MSU research project, disclose Outside Activities and Significant Financial Interests, including domestic and non-domestic Outside Activities related to the Covered Individual’s or Investigator’s Institutional Responsibilities. New employees will receive a notification from Kuali Research with instructions on how to complete a disclosure. Covered Individuals and Investigators must also submit an updated disclosure within thirty (30) days of acquiring any new Outside Activity, Significant Financial Interest, or other opportunity for tangible personal benefit. Covered Individuals and Investigators must provide all relevant information concerning disclosed matters as the information may be requested by a supervising authority for the purpose of evaluating and managing actual or potential Conflicts of Interest. Disclosures are completed in MSU’s Kuali Research System.
If a Covered Individual or Investigator is unsure whether their Outside Activity or Financial Interest relates to their Institutional Responsibilities or meets the definition of a Conflict of Interest or a Conflict of Commitment, they should disclose the Outside Activity or contact the Office of Conflict Disclosures and Management for further review. Further information related to disclosure is also included in the FCOI Standard Operating Procedure (FCOI SOP).
The Office of Conflict Disclosures and Management (CDM), in the Office of Research Regulatory Support (ORRS), will review all individual annual disclosures. Disclosures may be shared with the following to facilitate identifying Conflicts of Interest and Conflicts of Commitment: The Office of General Counsel, Procurement, Department Chairs, Deans, or Supervisors. The University shall respect the confidentiality of private financial and other confidential information supplied by faculty and shall not release this information publicly unless it is legally required to do so or the resolution or elimination of the conflict of interest requires public disclosure of the information (See Section V. (e), Board of Trustees Approval and CRC Procedures). Further information related to the review of conflicts and Financial Conflicts of Interest is also included in the FCOI SOP.
All Covered Individuals and Investigators who wish to engage in Outside Activities (excluding Scholarly Activities as defined in this policy), must submit an Outside Activity Approval Form and obtain approval before engaging in any Outside Activities during duty and non-duty periods.
Certain activities are expected of Covered Individuals and Investigators as part of their Scholarly Activities, as defined in this policy. Scholarly Activities are not regulated by this Section and do not require approval (even if a Covered Individual or Investigator receives payment for these services). Certain Scholarly Activities may require disclosure on the MSU COI disclosure.
In consultation with the Covered Individual or Investigator with the Conflict of Interest, the Office of Conflict Disclosures and Management shall draft a conflict management plan for any Outside Activity or Significant Financial Interest that is or may be a Conflict of Interest, Financial Conflict of Interest, or Conflict of Commitment if needed. The Office of Conflict Disclosure and Management shall refer conflict management plans to the MSU Conflict Review Committee (CRC) for review and approval.
The MSU CRC will determine whether a COI or COC exists, assess whether conflicts or potential conflicts are being appropriately managed, recommend conflict management plans, conflict management strategies, and corrective actions when necessary.
The MSU CRC membership is comprised of faculty representatives and non-voting administrators and representatives from offices at MSU including but not limited to: CDM, ORRS, MSU Technologies, Business Connect, Office of Sponsored Programs, and the Office of General Counsel.
The Office of Conflict Disclosures and Management shall maintain a copy of all conflict management plans. Further information related to conflict management is also included in the FCOI SOP.
Due to Michigan Law MCL - Act 317 of 1968, MSU’s Board of Trustees must approve any proposed agreement under any arrangement where the MSU employee seeks to participate in company-sponsored activity on behalf of MSU in the following instances:
Any non-compliance with this Policy shall be addressed by the relevant department/unit head. The relevant department/unit head should consult with the Office for Faculty and Academic Staff Affairs and the Office for the Vice President for Research and Innovation to best determine any educational and/or disciplinary actions to implement due to non-compliance with this Policy.
Any discipline will follow the relevant discipline policy for that employment category1. The goals of educational and/or disciplinary actions include, but are not limited to, reinforcing training, mitigating risks caused by noncompliance, and deterring further noncompliance.
1Relevant faculty discipline policies are located here:
Colleges, departments, and administrative units may adopt standards that are more, but not less, restrictive than those set forth in this policy. This policy is consistent with and is in addition to relevant federal and state law and University policies, as well as with unit policies not listed here. The following policies and guidance documents are supplemental to this policy and include important information pertinent to the information contained in this policy.
Enacted: June 13, 2025
Disclaimer: The additional links, resources, and references provided below are for informational purposes only and are not part of this Board of Trustees policy. They are intended to supplement understanding and provide context. Always refer to the most current and official version of the board policy for authoritative direction.
MSU's Conflict of Commitment Form
COI/COC Reference Guide
Guidance for Chairs and Supervisors
FAQs