Frequently Asked Questions

Frequently Asked Questions on Conflict of Interest and Conflict of Commitment Identification and Disclosure Policy

General Overview

• Why does MSU have a Conflict of Interest and Conflict of Commitment policy?

  MSU is committed to ethical conduct and transparency in all academic, research, and professional activities. The policy supports faculty participation in outside activities while ensuring those activities do not create a conflict of commitment (e.g., interfere with institutional responsibilities) or conflicts of interest.

• Who is covered by this policy?

  Individuals in the following roles are covered under the policy:

  • Faculty: Includes all individuals holding positions classified as Ranked Faculty, as defined in the Academic Hiring Manual – University Approved Positions/Ranks.
  • Executive Management: Includes all individuals holding positions designated as Executive Management, as listed in the Executive Management Position Titles.
  • Academic Administrators: All positions identified as Academic Administrators in the Academic Hiring Manual.
  • Investigators: Includes the Project Director or Principal Investigator, as well as any other individual responsible for the design, conduct, or reporting of research—regardless of title or position—or identified as a Covered Individual in a federal award.
• What is the difference between a Conflict of Interest and a Conflict of Commitment?

  A Conflict of Interest (COI) occurs when outside relationships could influence, or appear to influence, your professional judgment or responsibilities to the University.

  A Conflict of Commitment (COC) arises when a faculty member’s outside activities or external relationships may interfere with or compete against MSU’s educational, research, or service missions—or with the faculty member’s ability or willingness to meet their full University responsibilities. It can also involve obligations to improperly share information with outside entities or to withhold information from MSU or research sponsors.

• Who is required to obtain approval for outside activities?

  Individuals in the following roles must submit a disclosure and obtain approval before engaging in outside activities:

  • Faculty: Includes all individuals holding positions classified as Ranked Faculty, as defined in the Academic Hiring Manual – University Approved Positions/Ranks.
  • Executive Management: Includes all individuals holding positions designated as Executive Management, as listed in the Executive Management Position Titles.
  • Academic Administrators: All positions identified as Academic Administrators in the Academic Hiring Manual.
  • Investigators: Includes the Project Director or Principal Investigator, as well as any other individual responsible for the design, conduct, or reporting of research—regardless of title or position—or identified as a Covered Individual in a federal award.

Outside Activities, Approval, and Disclosure

• Do I need to report and receive approval for all outside activities?

  You are required to disclose and obtain approval for Outside Activities (as defined in the policy) that are related or similar to your professional expertise and fall outside of your MSU responsibilities—regardless of whether they are paid or unpaid, domestic or non-domestic. These activities must be submitted through the Conflict of Commitment Form. An exception is made for Scholarly Activities, as defined in the policy, as these do not require approval but may need to be disclosed. For examples of Outside Activities and Scholarly Activities, please see the definition in the Policy and also your College’s website for a list of examples.

  Activities that are not related to your professional expertise do not need to receive approval. For example, if your area of professional expertise is in agriculture, coaching a youth sports team would not require disclosure or approval.

• What are examples of activities I need to disclose?

  Examples include consulting, external teaching, research not managed by MSU, serving as an officer or board member for a company, participating in foreign talent recruitment programs, or starting a business related to your field. Refer to your College’s website for a list of examples.

• How do I know if an activity is related or similar to my Institutional Responsibilities?

  If the activity is in the general area of expertise for which you are employed by MSU, or if the activity involves your expertise as a researcher, is related to or overlaps with your MSU research, then it is likely related to your Institutional Responsibilities. Furthermore, if it is possible that you may make university decisions that could affect your outside interest or activities, or if the activity may influence your MSU duties, then it is likely related to your institutional responsibilities.

  For example, a chemistry professor who is compensated for playing the piano in a local restaurant or who is paid to referee youth soccer games, does not need to obtain approval for or to report such work under the Policy. However, the individual’s outside activities may not interfere with their Institutional Responsibilities and cause a conflict of commitment as defined in the Policy.

• Do I need to disclose and receive approval for activities during the summer or other non-duty periods?

  Yes. While time limitations do not apply during non-duty periods (e.g., summer for academic year appointments), you are still required to disclose outside activities for review and approval.

  MSU recognizes that faculty 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 may be an important part of their academic and professional pursuits.

  To ensure alignment with university policies, faculty are expected to disclose any external employment or professional commitments. This disclosure process allows the university to assess potential conflicts of commitment, such as compliance with intellectual property (IP) policies.

  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 faculty members' ability to pursue outside work.

• Do Scholarly Activities need to be disclosed?
  Many Scholarly Activities do not require disclosure or prior approval, but certain Scholarly Activities must still be disclosed in COI forms or grant applications. Scholarly Activities can also be added electronically in the same portal with Outside Activities. Examples of Scholarly Activities that require disclosure will be located on the landing page of the Conflict of Commitment form and your College’s website.
• What if I’m not sure whether an activity should be disclosed?
  When in doubt, disclose. Simply disclosing an outside or scholarly activity does not mean the activity will be a conflict of interest. You can also consult with your department chair, dean, or the Office of Conflict Disclosure and Management for guidance.
• When do I need to make a disclosure? 
  1. Annually: All faculty and staff who work on sponsored research must complete an annual conflict of interest disclosure in Kuali Research no later than one year after your initial disclosure or last annual disclosure, and every twelve months thereafter. 
  2.  Project based: Some federal regulations and policies require that each institution and investigator applying for, receiving, or being supported by those agency’s funds be compliant with rules regarding training and disclosure prior to applying for funds and the establishment of conflict of interest management plans prior to the expenditure of funds.  See FAQs relating to federal COI requirements. 
  3. Revising Disclosures: Disclosures must be updated within 30 days of acquiring or discovering any new outside activity or financial interest. 

Time and Effort Expectations

• How much time can I devote to outside activities during the academic year?

  Individuals on full-time appointments may spend up to an average of four days per month (during their duty period) on approved outside activities (paid and unpaid). This includes all outside activities and overload pay assignments.

• What is the difference between Overload work and Outside Activities?
  Overload work refers to assignments performed for the University—such as teaching, research, outreach, or academic/student support—that represent a significant increase beyond an individual’s regular responsibilities. In contrast, Outside Activities involve activities in the individual’s professional area of expertise that are performed for an external individual or organization, not affiliated with the University. Individuals may seek approval to engage in a combination of Overload work and Outside Activities, not to exceed an average of four days per month.
• I have a part-time appointment. Does the four-day average limit apply to me?

  Faculty with at least a 50% appointment may engage in outside activities on a prorated basis. Those with less than 50% appointments may not engage in outside activities during their designated MSU work time.

  For example, if you are a faculty member with a 20% appointment, you may not engage in any Outside Activities during the 20% time that you are working for MSU. That is not to say that you would not be permitted to engage in Outside Activities during the 80% time that you are not working for MSU. Instead, it means that you cannot use any of the 20% time that you are working for MSU on Outside Activities.

  To further explain, if you have a 75% appointment with MSU, then the four-day average limit is prorated, so you would have approximately 3 days on average per month in which you could use to engage in Outside Activities (in addition to the 25% time that you are not appointed to work for MSU).

• Does the four day average per month limit on Outside Activities include evenings and weekends?

  Yes. During duty periods, Covered Individuals are expected to devote their full professional efforts to the University, including weekends and evenings. Accordingly, Outside Activities performed during the evening or weekend count toward the total average of four days per month allowed by the policy.

  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.

• How is a day defined?

  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.

Pre-Approval Process

• What standards govern a University Administrator’s decision to grant or deny a Covered Individual’s request to engage in an Outside Activity?

  The standards that govern an administrator’s approval decision on outside activity requests include:

  The outside activity will enhance faculty member’s expertise or professional area of specialty. The outside activity will not interfere with the performance of the faculty member’s Institutional Responsibilities including, but not limited to teaching, research, service, accessibility and mentorship to students, or other contractual obligations to the University or to Research sponsors. 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, etc. The totality of all approved outside activities and overload pay assignments for the faculty member do not exceed a total average of four (4) days a month.

  When students or staff are involved in an outside activity, appropriate approvals are obtained, and safeguards implemented to ensure their participation is voluntary and aligned with university policies.

  When these conditions are met, approval is generally expected. If any condition is not met, the request should be reviewed further, and unit administrators should work collaboratively with the individual to determine whether modifications can address potential concerns. For further guidance, refer to the resource document, “Guidance for Chairpersons, School Directors, Deans, and Supervisors on Reviewing Outside Activity Requests”.

• Where do I submit an Outside Activities Approval Form?

  You may submit an Outside Activities Approval Form in Kuali Build, MSU’s electronic system.

• What information is needed to submit an Outside Activities Approval Form?

  Basic information including the name of the outside entity, your involvement, dates of the activity, and other COI related questions.

• Who will review my Outside Activities Approval form?

  Department chairs, school directors, or supervisors and deans/heads of a major administrative unit (“University Administrators”) shall review all Outside Activities requests for approval. Requests for approval for an Outside Activity will be made through the Covered Individual’s primary college.

• What will the University Administrators do with my Outside Activity Approval form?

  The University Administrators will review and will either approve or deny the request, or may request further information.

• Does my approved Outside Activity need to be disclosed to my MSU Conflict of Interest disclosure form in Kuali Research?

  At this time, Outside Activities should also be added to your Conflict of Interest disclosure in Kuali Research and in the Conflict of Commitment form in Kuali Build. In the coming months, this process will evolve and improve incrementally. Furthermore, Covered Individuals are required to submit an annual COI disclosure form annually, and also must update your disclosure within 30 days of acquiring a new financial interest, or any other changes regarding a previously disclosed activity.

• My unit denied my Outside Activity Approval Form. What are my options?

  If a request to engage in an Outside Activity is denied, the University administrator shall provide the Covered Individual or Investigator with written reasons for the denial. A Covered Individual or Investigator may not challenge a decision to deny approval for an Outside Activity through the Faculty Grievance Policy unless the Covered Individual or Investigator alleges that the denial is contrary to University, college, department, school, or unit policy or established practice.

• An Outside Activity or financial interest needs review by the Conflict Review Committee. What does this mean?

  Each university administrator or dean/head of the major administrative unit may consult and collaborate with the Office of Conflict Disclosure and Management if they identify a potential conflict by a Covered Individual or Investigator. In certain instances, potential conflicts may require a conflict management plan (CMP) to manage a potential conflict. This will also require review by the University’s Conflict Review Committee (CRC).

Other Considerations

• Under what type of circumstances might approval for an Outside Activity be terminated?

  The Policy provides that approval for Outside Activities is subject to termination at any time the University considers such action to be advisable. Such termination might occur if circumstances have changed and the Outside Activity no longer meets the conditions for approval. For example, approval might be terminated when the outside work interferes with the performance of the faculty member's duties or adversely affects the University's interests or violates University policies.

• How can a faculty member challenge the denial or termination of approval to engage in an Outside Activity?

  A faculty member may challenge a decision to deny or terminate approval for an Outside Activity through the Faculty Grievance Procedure if the faculty member alleges that the denial is contrary to this Policy, to another University policy, or to established practice, or that it is an unfair application of this Policy.

• Do different colleges at MSU have different rules?

  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.

• What are examples of conflicts of interest regulated by this Policy?

  For example, a potential conflict of interest could in actuality or in appearance affect a Covered Individual or Investigator’s judgement, could bias the direction of research, could influence decisions or actions related to teaching, students, appointments, promotions, use of University resources, interaction with research subjects, or other University matters, or could result in a benefit to a Covered Individual, Investigator or their Family Member, at the expense of the University.

• Where do I find other related policies?

  Related policies are listed in Section VII. Related Policies and Information in the MSU Conflict of Interest and Conflict of Commitment Identification and Disclosure Policy. For example, the following policies and guidance documents are supplemental to this policy and include important information pertinent to the information contained in this policy:

  • Dual Appointment Policy
  • University Procurement and Logistics Conflict of Interest Policy
  • HRPP Manual Section 10-1, Conflict of Interest
  • Faculty Authored Works Assigned to Students and Perceived Conflicts of Interest
  • Resources for Faculty Disclosures
  • Conflict Review Committee Operating Procedures
  • MSU Patent Policy
  • MSU Copyright Policy
  • Prohibition of Participation in Malign Foreign Talent Recruitment Programs
  • Sabbatical Leaves of Absence
  • Conflict of Interest in Employment
• Are graduate and post-doctoral fellows required to disclose interests?
  The policy is addressed to faculty, executive management, academic administrators, and investigators.  It may be the case that this policy could apply to other individuals, including graduate students or post-doctoral fellows who meet the definition of an Investigator as defined in the Policy. This responsibility would be determined by the Project Director or Principal Investigator, who would identify the student as Key Personnel within the Proposal Development document.  In that case, the student would be required to complete a COI disclosure and resolve any conflict of interest. Students should be able to log into the Kuali COI portal using their MSU NetID the same as MSU employees.  Contact OSP/CGA or cdm@msu.edu for assistance.
• What happens if something I disclose is a conflict of interest? 

  The Office of Conflict Disclosure and Management (CDM) will notify you of the potential conflict.  They will work with you and your chair and dean to develop a management plan if necessary.  CDM makes a recommendation of appropriate action. If further management is needed, CDM will, 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 potential Conflict of Interest or Financial Conflict of Interest. 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.

  Once a management plan is approved, the plan will be signed by the Covered Individual, their chair, dean, and the VPRI.

• What is a conflict management plan (CMP)?

  It is an agreement that identifies restrictions on and expectations of the Covered Individual for the purpose of reducing or managing a conflict of interest.  The purpose of the CMP is to ensure that the design, conduct, and reporting of research will be free from bias or apparent bias. Management plans may include the following requirements (non-exhaustive list): 

  • Public disclosure of the COI when presenting or publishing research; to staff members working on the project; to MSU’s Institutional Review Board, etc.; 
  • Disclosure to human subjects participating in research; 
  • Appointment of an independent monitor empowered to take measures to protect the design, conduct, and reporting of the research against bias; 
  • Modification of the research plan; 
  • Change of personnel responsibilities or disqualification of personnel from participation in all or a portion of the research;  

  
  The Covered Individual and their chair and dean will have the opportunity to review and comment on the CMP before it goes to the CRC for assessment and final approval by the Vice President for Research and Innovation. Conflict Management Plans are periodically reviewed for compliance and updating as appropriate by CDM and staff.
• What happens if I fail to file a disclosure required under the Policy?

  Without a required disclosure, project or grant applications will not be submitted to the funding entity. MSU will not release funding until the disclosed conflict has been managed. 

  Additionally, a faculty member who violates this Policy is subject to disciplinary action. The VPRI, in consultation with OCDM, shall establish a mechanism for investigating concerns or allegations regarding unreported significant financial interests and other opportunities for tangible personal benefit. 

  Some federal funding agencies have additional rules and regulations regarding non-compliance with their policies and regulations.

• Can students work for a company in which their MSU advisor has a financial interest?
  1. A student may work for a company in which their MSU advisor has a financial interest if the Faculty Member obtains prior approval from written permission by their Dean based on justification by Faculty Member and endorsement by 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. 
  2. 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.
• Can I be the PI for an entity outside of MSU? 

  Yes, if you reduce your employment at MSU accordingly (or have an employment agreement between MSU and the entity for the appropriate effort). Additionally, you would not be able to serve as MSU subaward PI if you are also the PI for the outside entity

• Will this information be kept private? 

  MSU respects the confidentiality of private financial information and other information reported by faculty and will not release this information publicly unless: 

  • It is legally required to disclose the information. 
  • It is subject to release under the State of Mihcigan Freedom of Information Act (FOIA). 
  • The resolution or management of the conflict of interest requires public disclosure of the information. 
  • The faculty member consents to its public disclosure. 
  • Some federal regulations require MSU to inform the public on our website that information regarding conflicts related to agency funding is available to the public.  
  • Disclosure information may be shared within the U-M, as described in the Policy.

Board of Trustees (BOT) Approval

MSU submits certain contracts involving faculty financial interests for approval to the MSU Board of Trustees.  MSU employees must disclose ownership interests in or managerial control over outside legal entities. When conflicts of interest arise, MSU obtains Board of Trustees review and approval before moving forward with the arrangement.

• What scenarios does the Board of Trustees review? 

  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:

  • an MSU employee serves as an officer or employee;
  • an MSU employee is a partner, member or employee of any firm, co-partnership, or unincorporated association that has solicited business from MSU;
  • an MSU employee owns more than 1% of total outstanding stock (if valued at over $5000 in a calendar year) in a privately owned corporation that has solicited business from MSU; or 
  • an MSU employee owns stock valued at over $25,000 in a publicly traded company that has solicited business from MSU.
• How do I obtain Board of Trustees approval? 

  A term sheet is submitted to the Office of Conflict Disclosures and Management (cdm@msu.edu) in order to be added to the Board Agenda for approval at the corresponding BOT meeting date. Note: if you have not previously disclosed this financial interest to OCDM and it requires a management plan, submission to the Board may be delayed until the Plan review and approval process is complete. 

  CDM works with the relevant MSU departments to identify due dates for the term sheets to be sent to CDM. If a financial interest identified in a term sheet has not been previously disclosed to CDM, it might not be reviewed and managed in time for the Board meeting that corresponds to the Term Sheet due date. In those instances, the transaction will be pushed to a future regularly scheduled meeting. Please reach out to cdm@msu.edu with any questions related to these term sheets. 

  Process for De Minimis Value Agreements (MTAs, CDAs, etc.): If a contract is worth less than $250, the employee must submit an affidavit to the Board using the De Minimis Affidavit Form. MSUT will compile the list of de minimis disclosures prior to each meeting and maintain a record of such disclosures for Board or public review.  This process is instead of full Board review and approval.  

  Process for Agreements Directly Between Employee and MSU: If the contract is between MSU and an employee directly (rather than a company in which the employee has an interest) and the value of the contract is above $5,000, there are two steps for approval.  First, the MSU employee and the subject matter of the contract are identified and made public at a public Board meeting (First Read).  Second, at a subsequent public Board meeting, the Board will review the terms of the specific contract under review (Use term sheet noted above) (Second Read). First Read is only required on the initial disclosure of the MSU employee’s interest.  Subsequent contracts with the same employee only require a Second Read.

Outside Activities and Faculty in Medical Colleges

• Does the new COI/COC policy apply to clinical faculty in the Colleges of Human Medicine, Osteopathic Medicine, and Nursing?

  Yes, if the clinical faculty fall under the definition of “Covered Individuals” in the COI/COC Policy (e.g., ranked faculty, executive management, academic administrators, or Investigators) and meet other eligibility requirements (e.g., over 50% FTE), then they are included. See Section V.7.

• How do Outside Activities apply to clinical faculty in the Colleges of Human Medicine and Osteopathic Medicine?

  Faculty in the Colleges of Human Medicine and Osteopathic Medicine cannot provide patient care through Outside Activities in the state of Michigan. Faculty in these Colleges can perform other types of Outside Activities inside the state of Michigan (e.g., participation in a faculty start-up company, etc.) so long as all other requirements of the COI/COC Policy are met.

  Faculty in the Colleges of Human Medicine and Osteopathic Medicine (excluding PA Medicine), who hold a 50% FTE appointment or more, may engage in Outside patient care, or administrative or consulting activities significantly related to patient care under the following conditions: (1) the work is performed outside of the state of Michigan; (2) the work is performed during vacation time from MSU; (3) the faculty provides proof of malpractice coverage to MSU and MSU Health Care, Inc. The 4 day limit would not apply to these Outside Activities performed outside the state of Michigan, so long as all 3 conditions were met.

• How do Outside Activities apply to faculty in the College of Nursing and Physician Assistant Medicine in Osteopathic Medicine?

  Faculty in the College of Nursing or Physician Assistant Medicine in the College of Osteopathic Medicine, who have a 50% FTE appointment or higher, may engage in Outside Activities (within the state of Michigan) including patient care and/or administrative or consulting activities significantly related to patient care if the work is being performed as a registered nurse (not an advanced practice registered nurse. If the work is being performed as an advanced practice registered nurse or physician assistant, the work may be performed if the following conditions are met: (1) the work is required to maintain certification; (2) the practice plan (MSU Health Care, Inc.) cannot offer placement; and (3) proof of malpractice insurance is provided to MSU.

Policy Transition, Timing

• When do the new requirements in the policy take effect?

  The new requirements take effect immediately. However, we recognize that the 2025–26 academic year will be a transitionary period where faculty will adjust to the new policy.

  • Faculty should begin submitting disclosures and requests for approval for both paid and unpaid activities this year.
  • The 4-day/month limit will apply with flexibility as faculty adjust existing commitments.

  
  We recognize that many faculty already planned commitments under the prior policy, which only limited paid activities. The transition period ensures:

  • Faculty are not penalized for plans already in place.
  • Departments and Policy Implementation Liaisons have time to build consistent practices.
  • Everyone has time to adjust to the new expectations.
• What do I do if I recently submitted an MSU Outside Work for Pay paper form for an activity? Do I need to re-submit via the new electronic form?
  • Activities approved under the previous Outside Work for Pay policy do not need to be re-submitted for approval at this time.
  • During the transition to the new policy, if your activity continues beyond August 15, 2026, please submit an electronic form for approval by August 16, 2026, in order to be in compliance with the new Conflict of Interest and Conflict of Commitment Identification and Disclosure Policy.
  • Going forward, approval requests for Outside Activities must be submitted annually or when there is a change in circumstances.
• Is there an annual requirement to request approval for outside activities?

  Yes. If you wish to continue an outside activity beyond the current academic year, you must re-request approval for the next academic year.

  • The reporting period runs from August 16 to August 15 each year.
  • Renewing your request ensures that your activity is reviewed in light of any new commitments, policy updates, or changes to your university responsibilities.