Section XI

XI. SPONSORED PROJECTS

A. Overview
  1. The guidelines in this section are intended to assure that the design, conduct and reporting of research and other sponsored projects conducted by Central Michigan University are not biased by any conflicting financial interest of persons involved in carrying out the sponsored projects. To achieve this goal, the University is committed to:

    1. identifying significant financial interests that would reasonably appear to affect the sponsored research and

    2. addressing actual, perceived, and potential conflicts.

    The guidelines are to be used for identifying and resolving actual, perceived or potential faculty/staff conflicts of interest pertaining to sponsored projects.

  2. These guidelines apply to:

    1. all faculty and staff involved in sponsored projects funded by federal, state or local government agencies, private foundations, or commercial/corporate sponsors, and

    2. sub-grantees, contractors or collaborators working under the auspices of Central Michigan University on sponsored projects funded by federal, state or local government agencies, private foundations, or commercial/corporate sponsors, and

    3. purchase orders and subcontracts issued by Central Michigan University under its sponsored projects regardless of the source of funds.
 
B. Disclosure Requirements
  1. Participating faculty/staff members in a sponsored project include:
     
    1. the project director/principal investigator,

    2. co-project director/co-principal investigator, and

    3. any other person at the University who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding through a sponsored project.

  2. Each faculty/staff member participating in a sponsored project covered by these guidelines must disclose whether he/she has external affiliations that may constitute an actual, perceived or potential conflict as described in any of the criteria outlined in paragraph A-D on the first page of the guidelines.

  3. No later than the time when a grant proposal is submitted to the Office of Research and Sponsored Programs for transmittal to a specified funding agency, each participating faculty/staff member must have on file with the Office of Research and Sponsored Programs a current, completed Financial Disclosure Statement Regarding Sponsored Projects (see Attachment B - Parts I(a)of Conflict of Interest Guidelines).

  4. Prior to the finalization of any contracts or subcontracts issued to the University, each participating faculty/staff must have on file with the Office of Research and Sponsored Programs, a current, completed Financial Disclosure Statement Regarding Sponsored Projects (see Attachment B - Part I(b) of Conflict of Interest Guidelines).

  5. In order to insure that an external subcontractor does not have a conflict of interest related to the particular project, the Principal Investigator on a project is responsible for obtaining a completed Financial Disclosure Statement Regarding Sponsored Projects (see Attachment B - Part II of Conflict of Interest Guidelines) from every subcontractor who will be working on the project. These statements must be submitted to and reviewed by the Office of Research and Sponsored Programs prior to the University signing any agreements with the subcontractor(s).

  6. A negative disclosure (one that reveals no conflict of interest) will be signed by the Office of Research and Sponsored Programs and retained in the Office of Research and Sponsored Programs.

  7. A positive disclosure (one that requires additional review) will be reviewed initially by the Office of Research and Sponsored Programs in an attempt to resolve any actual or potential conflicts of interest. In those instances where the conflict cannot be resolved at the initial review stage, positive disclosures will be referred to a Conflict Review Committee for additional review. This committee consists of the Assistant Vice President for Research, Assistant Vice President for Academic Administration and the Director of Purchasing, advised by the University Counsel. In the event that the committee determines that additional expertise is necessary, it reserves the right to invite persons with such expertise to participate in its discussions. When resolved, the positive disclosure form and any materials relating to the resolution of the actual or potential conflict of interest will be retained in the Office of Research and Sponsored Programs.

  8. The Office of Research and Sponsored Programs will also arrange to have all financial disclosures updated during the period of the faculty/staff member's sponsored projects, either on an annual basis or as new reportable significant financial interests are obtained. It is the faculty/staff member's responsibility to notify the Office of Research and Sponsored Programs of any conflict of interest that arises during the implementation of the sponsored project when none was present at the time the project award was first accepted.
Note: It is not the intent of the Office of Research and Sponsored Programs to delay the submission of a sponsored project because of problems relating to the disclosure form. However, all disclosures must be completed and all actual, perceived, or potential conflicts must be resolved prior to the University's expenditure of any funds under the sponsored project or issuance of a purchase order or subcontract for the acquisition of goods and services under a sponsored project.
 
C. Responsibilities of the Conflict Review Committee
In reviewing positive disclosures forwarded by the Director of the Office of Research and Sponsored Programs, the Conflict Review Committee will be guided by the following practices and may apply them whenever appropriate:
  1. Determine, from the disclosure form, whether a significant financial interest could directly and significantly affect the design, conduct or reporting of funded research.
  2. Assure adherence to all relevant and existing University policies as outlined in such publications as the Faculty Handbook, the PA Handbook, the SO Handbook, the ORSP Handbook, and the Standard Practice Guide. The committee should also refer to and comply with provisions in the Agreement between the University and the CMU Faculty Association, as well as any other University documents that it may consider relevant and appropriate.
  3. Consider the nature and extent of the financial interest in the relationship between the faculty/staff member and the external organization.
  4. Give special consideration to the terms and conditions of sponsored project agreements that may mitigate or complicate the specific situation under review.
  5. Consult with and obtain additional information from the faculty/staff member that either the Conflict Review Committee or the faculty/staff member feel may be helpful in resolving an actual or potential conflict.
  6. Act in a timely manner so as not to delay unduly the conduct of the sponsored project.
  7. Conclude that the University may take one of the following actions:
    1. Accept the sponsored project award.
    2. Do not accept the sponsored project award.
    3. Accept the sponsored project award subject to:
      1. public disclosure of significant financial interests; or
      2. making suitable modifications in the research plan; or
      3. arranging to have the faculty/staff member's research monitored by independent reviewers; or
      4. divestiture by the faculty/staff member of significant financial interests; or
      5. the assignment of a different faculty/staff member without a financial interest to take responsibility for the sponsored project; or
      6. severance of any relationship that creates an actual, perceived or potential conflict of interest on the part of the faculty/staff member or the faculty/staff member's Family/Household.
 
D. Compliance
  1. The University requires all faculty/staff involved in sponsored projects to comply fully with all requirements of these guidelines. Violations of the guidelines include, but are not limited to:
    1. failure to file a disclosure form;
    2. filing of an incomplete, erroneous or misleading disclosure form that the person knew or should have known was incomplete, erroneous or misleading;
    3. willful concealment of financial interests; or
    4. failure to provide additional information as required by the Conflict Review Committee.
  2. The Conflict Review Committee will review all allegations of violations and will make recommendations regarding the imposition of sanctions to the Provost or appropriate vice president. Sanctions imposed will be commensurate with or appropriate to the violation.
  3. Any faculty/staff member against whom an allegation of violation is made shall be accorded due process as provided in any applicable collective bargaining agreement or other appropriate procedures at Central Michigan University.
 
E. Confidentiality and Records Retention
  1. The Office of Research and Sponsored Programs shall maintain the maximum confidentiality allowed by law concerning the records pertaining to each disclosure. Access to such records will be limited to the staff of the Office of Research and Sponsored Programs in carrying out their duties, the faculty/staff member, the Conflict Review Committee, the Provost, and others on a "need to know" basis.
  2. The Office of Research and Sponsored Programs will comply with all federal reporting regulations regarding conflict of interest. This includes, but is not limited to the Public Health Services' (PHS) requirement that the University report to PHS, prior to the expenditures of PHS funds, the existence of a conflicting interest and assure that the interest has been managed, reduced, or eliminated. In addition, when required by the federal agency, the Office of Research and Sponsored Programs will inform a specific funding agency whenever the University is unable to satisfactorily manage/resolve an actual, perceived, or potential conflict of interest.
  3. The Office of Research and Sponsored Programs will also maintain records of all financial disclosures and of all actions taken to resolve actual, perceived or potential conflicts of interest until at least three (3) years after the termination or completion of the sponsored project to which they relate, or the resolution of any action involving those records, whichever is longer.
 
Note: Certain sponsors, particularly federal agencies, may have requirements that are more rigorous than those outlined in these guidelines with regard to the timing and frequency of faculty disclosures and other provisions as well. In the case of such discrepancies, the sponsors' requirements will generally prevail.
 

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