Wichita State University employees are encouraged to interact with business, industry, public and private foundations, and government agencies to facilitate professional development. They are also encouraged to promote the expansion and application of knowledge gained through research. It is important that these activities are conducted in a manner that avoids or minimizes conflicts of time commitments and conflicts of interest.
Policies and Reporting:
The Kansas Board of Regents (KBOR) and WSU policies require that all University employees (except student employees and graduate students) complete and submit a yearly report of financial interests and time commitments. All University employees must complete a disclosure even if the employee has no involvement in sponsored programs and/or no conflicts of time interest. Additionally, it is the responsibility of the employee to make and file ad hoc reports to disclose any instances of conflict (actual or potential) as soon as they become known, and in any instance, not later than thirty (30) days after discovery or acquisition of the actual or potential conflict of time commitment or interest.
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CONFLICT OF INTEREST - DEFINITIONS
A conflict of interest exists when a person’s outside or private interests affect – or appear to affect – their Institutional Responsibilities and judgment as a Wichita State employee
A conflict of time commitment may exist when an employee's external activities, performed with or without pay, involve a commitment of time that may compete, or appear to compete with the employee's obligations to the University.
“Institutional Responsibilities” involve a variety of scholarly and professional obligations carried out on behalf of the University. These may include, but are not limited to teaching, research, scholarship, professional practice and service, etc. These responsibilities may or may not be included in your official position description. So, an easy way to determine your Institutional Responsibilities is to ask yourself “what do I do for or on behalf of Wichita State University?” That long list that you come up with? Those are your Institutional Responsibilities that could present a conflict.
For purposes of conflict of interest, these interests are defined as “all holdings greater than $5,000 or more than 5% ownership.”
These activities are defined in Section G of WSU Policy 3.04 / Commitment of Time, Conflict of Interest, Consulting and Other Employment
Lobbying activities include, but are not limited to any written, oral, or electronic communication regarding any proposed or adopted federal legislation, rule, or executive order, or the administration of any federal program with any covered executive or legislative branch official. This includes the negotiation, award, or administration of any federal contract, grant, loan, permit, or license.
Reimbursed or sponsored travel is related to the investigator's Institutional Responsibilities.
A collaboration is basically anything: formal partnerships with international/domestic scholars, agreements to explore areas of common interest, student and faculty exchanges, joint publications, gifts from donors, contracts with vendors, etc. A collaboration can exist even if there is no money involved.
REPORTING - GENERAL
Wichita State University's Conflict of Interest Policy, as well as the Kansas Board of Regents Conflict of Interest Policy, require certain members of the Wichita State community to complete a COI disclosure annually. The COI disclosure form collects information related to significant financial interests, conflicts of time commitment, supervisory conflicts, gifts, and foreign influence.
The new annual COI cycle runs between April 1 and March 31. Annual reporting is conducted electronically via myWSU. In April, when the annual cycle begins, Wichita State employees will receive an email with instructions on submission. All disclosures will be due by April 30.
All WSU personnel participating in research or sponsored projects must have a current COI Disclosure on file prior to proposal submission and/or award acceptance.
Maybe. Per Wichita State and KBOR policy, employees must disclose and current or prospective situations that may raise questions of conflict of interest or time commitment as soon as situations become known. For example, if you complete your annual disclosure during the month of April and report no conflicts, but in October of that same year, you are engaging in outside consulting, you will need to update your COI disclosure. If nothing changes from the time you submit your COI disclosure until it expires, you do not need to submit any updates in the interim. You must update your COI Disclosure form within 30 days of a change.
The determination regarding whether or not you have conflicts is not a self-determination but is instead made by the institution. In many instances, the perception of conflict is a critical factor to consider. Therefore, the institution does not ask whether you have “a conflict,” but rather asks employees to provide a list of your financial and other outside interests and then evaluates these against University responsibilities (i.e., research, teaching, etc.) to determine if these interests create potential conflicts.
No. You are thinking of the Kansas Governmental Ethics Commission “Statement of Substantial Interest.” The SSI asks questions similar to Wichita State’s COI disclosure, but they are not the same disclosure. (And before you ask – yes, we’ve checked. One cannot be substituted for the other).
No. WSU does not need the financial information of any external entity. You are simply required to fill out the questions as it relates to your (or your spouse, domestic partner, dependent child(ren), household member, or associated entity) financial or managerial interest.
Generally speaking, on the annual disclosure form, you will be asked to report financial and managerial interests; outside employment/collaboration; intellectual property; governmental ethics; sponsored or reimbursed travel; supervising relatives; and foreign collaboration. Please read the questions carefully. Reading the questions carefully and, if necessary, clicking on any hyperlinks provided, should give you enough guidance on how to answer the question and what or how much information to provide. See COI Disclosure Chart for helpful examples
Yes. Certain activities are exempt and do not need to be reported on the COI disclosure. See “Conflict of Interest: What Not to Disclose”
Yes. The interests of a spouse or dependent are reportable if they meet the reporting criteria and threshold. That is, if they are related to your Institutional Responsibilities (not your spouse’s or dependent’s Institutional Responsibilities, in the event they work for Wichita State).
You may disclose this in the last section of the Disclosure form under “other.” When in doubt, you are encouraged to disclose.
REVIEW AND MANAGEMENT
All COI disclosure are reviewed by staff in the Office of Research Compliance. The University is also in the process of creating a Conflict of Interest Review Board. COI disclosures with potential conflicts are referred to these two units for review. We will keep you up to date on the Review Board.
The Office of Research Compliance, in conjunction with the COI Review Board, carefully review all COI disclosures to determine whether an interest could create a conflict of interest. When reviewing disclosures, they will consider a number of factors including, but not limited to the magnitude of the financial interest, the degree of overlap between the external interest and Institutional Responsibilities, and whether the external interest could affect University research or educational activity. They also take into consideration perception of the external interest in relation to Institutional Responsibilities.
In general, a conflict of interest exists when an outside interest could compromise, or has the appearance of compromising, the professional judgment of an employee when designing, conducting, or reporting research, when teaching, and when carrying out general University duties and responsibilities. The existence of a conflict of interest does not imply any wrongdoing. Conflicts of interest are not in and of themselves unethical or impermissible. Indeed, they are often unavoidable, and in many cases can be appropriately managed or reduced to an acceptable level. However, employees should be cognizant of the fact that any outside activity, interest, or interaction with an outside entity has the potential to create conflicts, whether real or perceived. Recognition of potential conflicts, and sensitivity to how personal, financial, and other relationships can be perceived by others, are critical parts of managing conflicts.
Not necessarily. Having a conflict of interest does not automatically prohibit you from participating in external activities. In most instances, a conflict of interest can be appropriately managed so that you can, for example, continue to participate in a research activity while keeping your financial or outside interest. In some rare instances the conflict may be such that it cannot be appropriately managed. In general, your outside activities and interests should not prevent you from carrying out your research activities, teaching, and other Institutional Responsibilities.
In many instances, a conflict of interest can be resolved by simple disclosure. In other instances, the conflict may require a management plan to reduce, manage, or eliminate any conflict. If a management plan is required, the Office of Research Compliance will develop a management plan in cooperation with the employee to address the conflict.
Federal regulations require certain individuals to “disclose the occurrence of any reimbursed or sponsored travel related to their institutional responsibilities . . .” See 42 CFR 50.603.
Sponsored or reimbursed travel that should be disclosed includes but is not limited to the following:
- Reimbursed or sponsored travel related to Institutional responsibilities (including the purpose of trip, sponsor/organizer, destination, duration). Exceptions for travel are listed in the next section.
- Travel that is reimbursed or paid directly for consulting.
- Travel that is reimbursed or paid directly by a for-profit or non-profit organization for a conference, or to participate in a meeting.
- Travel that is reimbursed or paid directly when the investigator has a financial interest in that entity
The types of sponsored travel that do not need to be disclosed include:
- Travel that is funded by a sponsored award to Wichita State;
- Travel that is reimbursed to you through Wichita State;
- Travel that is reimbursed or paid directly by a federal, state, or local government agency;
- Travel that is reimbursed or paid directly by an institution of higher education as defined at 20 U.S.C. 1001(a);
- Travel that is reimbursed or paid directly by an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education
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The Council on Governmental Relations (COGR) published “Recognizing and Managing Personal Financial Conflicts of Interest” as a resource guide for researchers and research universities.
Publication Disclosure Statements:
Public disclosure is a management plan element that serves to protect investigators and WSU against any allegations of malfeasance by identifying and disclosing in an open and transparent way, all potential dual or competing interests that the investigator may have or appear to have in relation to his research. For more information about situations when disclosures should be made and specific language samples, please see “Publication Disclosure Statements for Conflicts of Interest.”
To take WSU’s online COI training, please visit our CITI Online Training page.
WSU Policy 3.04 / Commitment of Time, Conflict of Interest, Consulting and Other Employment
WSU Policy 3.16 / Employment of Relatives
WSU Policy 9.22 / Disclosure of Financial Conflicts of Interest for Public Health Service Supported Investigators
Kansas Board of Regents Board Policy Manual
National Institutes of Health Financial Conflict of Interest
National Institutes of Health Research Integrity
National Science Foundation Conflicts of Interest
State of Kansas Governmental Ethics Commission