What is required?

The UM Objectivity in Research Policy requires that Investigators disclose any significant financial interest that may present a conflict of interest in relationship to externally sponsored projects. Such disclosures must be made prior to the submission of a proposal for funding. It likewise requires that conflicts of interest be satisfactorily managed, reduced, or eliminated prior to the expenditure of the award or within 60 days of their identification for conflicts disclosed subsequent to an award. If a newly reportable significant conflict of interest arises at any time during the period after the submission of the proposal through the award period, the filing of a disclosure is also required, at that time or at least annually.

Who is covered?

Investigator is defined in the policy as the principal investigator or project director, co-principal investigators, and any other person at the University who is responsible for the design, conduct, or reporting of research, educational or service activities funded, or proposed for funding, by an external sponsor. In this context, the term Investigator includes also the Investigator’s immediate family (spouse, child, parent, or sibling; OR spouse of a child, parent, or sibling) either individually or in combinations with each other. External sponsor means any granting agency outside the University, including both governmental and non-governmental sponsors.

What must be disclosed?

Each Investigator shall disclose all Significant Financial Interests:

1. that would reasonably appear to be affected by the research, educational or service activities funded, or proposed for funding, by an external sponsor; or
2. in entities whose financial interests would reasonably appear to be affected by such activities.

What is covered?

Significant Financial Interest means a personal and pecuniary interest, direct or indirect, accruing to a public servant or his/her immediate family (see above), either individually or in combinations with each other, but not limited to: salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights). The term does not include:

1. Salary, royalties, or other remuneration from the University as an employee;
2. Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
3. Income from service on advisory committees or review panels for public or nonprofit entities;
4. Ownership of any interest of less than ten percent (10%) [5% ownership for NIH grants] in a business where the aggregate annual net income to you or your immediate family is less than One Thousand Dollars ($1,000.00);
5. Ownership of any interest of less than two percent (2%) in a business where the aggregate annual net income to you or your immediate family is less than Five Thousand Dollars ($5,000.00).

Disclosure Procedures

1. All Investigators must disclose their Significant Financial Interests as defined in A. and B. above utilizing the General Significant Financial Interest Disclosure Form for both PHS and Non-PHS Grants and Contracts (General SFI Disclosure Form) and attaching supporting documentation. The completed form and documentation must be submitted to the Office of Research and Sponsored Programs with the proposal and The University of Mississippi Transmittal Sheet for Sponsored Projects. Supporting documentation should be sealed in an envelope marked confidential and must accompany the Disclosure Form.
2. Resolutions to conflicts of interest will be incorporated in a Memorandum of Understanding (MOU) that is executed between the Investigator(s), the Investigator’s cognizant University official (usually a dean or director), and the Vice Chancellor for Research and Sponsored Programs prior to expenditure of award or within 60 days of their identification for conflicts disclosed subsequent to an award.

Two Common Example Situations that Require Conflict of Interest Management Plans

• The faculty member assigns students, postdoctoral fellows, or other trainees or employees to projects of interest to or supported by a business (through sponsored research or a contribution) in which they, an immediate family member, or an associated entity has a financial or business interest (other than royalty income).
• The faculty member or his or her department receives University-supervised sponsored research support or contributions (in dollars or in kind) from a business in which they, an immediate family member, or an associated entity has a financial or business interest.
   

Guidance on Developing Your Conflict of Interest Management Plan