E-900.7 Conflict of Interest in Federally Funded Projects

This Procedure aims to protect the integrity of federally funded grant projects by managing, reducing, or eliminating potential conflicts of interest. College Policies C-370 – Employee Code of Ethics and C-600 – Gifts, Gratuities, Honorariums, and External Compensation outline Employee expectations related to conflict of interest regarding personal benefit, outside employment, acceptance of gifts, and position use. Additionally, Employees designated as grant managers, project directors, principal investigators, co-principal investigators, and other key personnel on federal grants are to disclose significant financial interests annually or as new potential conflicts arise. This includes grants funded directly by federal agencies and those that “pass through” other entities or are sub-granted to the College.

Submission of the Financial Disclosure Form for Federally Funded Grants

• To ensure satisfactory compliance with the conflict-of-interest mandates under federally funded grants, Employees who serve as key personnel on federal grant applications must complete the Financial Disclosure to Avoid Conflict of Interest in Federally Funded Projects form.

• Key personnel are those individuals responsible for the design, conduct, or reporting of research or education activities funded or proposed for funding by a federal grant.

• The form must be completed and submitted to the Grants Office (GO) before submitting a proposal and updated if needed before the expenditure of any grant funds. Once the grant period begins, the form must be updated annually or when those key personnel know of new reportable significant financial interests. Significant financial interest includes anything of monetary value received from non-college sources that could potentially appear to affect the project, including but not limited to:

  • Salary or other payments for services (e.g., consulting fees or honoraria) anticipated over the next 12 months, which, when aggregated for the investigator and the investigator’s spouse and dependent children, exceed $10,000.

  • Equity interest (e.g., stocks, stock options, or other ownership interests) that, when aggregated for the investigator and the investigator’s spouse and dependent children, exceed $10,000 in value or represent more than a 5% ownership interest in any single entity.

  • Intellectual property rights (e.g., patents, copyrights, and royalties from such rights).

  • Participation (as an officer, director, partner, trustee, employee, advisory board member, or agent) in any entity funding or providing goods and services to a project.

  • Other significant financial interests.

Disposition of the Forms

• Once the forms are completed and submitted to the GO, the Executive Director of Institutional Research and Effectiveness will review them for potential conflicts of interest.

• If a potential conflict of interest exists, the Executive Director of Institutional Research and Effectiveness will confer with the Vice President of Academic Affairs and the Vice President of Finance and College Operations to review the situation further and recommend action.

• Those Employees will work with key personnel to manage, reduce, or eliminate potential conflicts and report conflicts to funding agencies as required.

• The GO will retain records of all financial disclosures and actions the College took regarding each conflict of interest for at least three (3) years from the grant's close.

Any Employee who knows of, or could reasonably have been expected to know of, and deliberately fails to disclose a potential conflict of interest shall be subject to disciplinary action ranging from reprimand to discharge.