4300P Investigator Significant Financial Interest Disclosure (Procedures)
Original Date: 3/1/1998 * Last Revision Effective: 9/11/2012
Policy Contact: Vice President, Administrative Services
The following procedures are established to meet the requirements for implementing policy #4300 – Investigator Significant Financial Interest Disclosure.
When submitting a proposal to an external sponsor, each investigator is require to disclose to the college the following:
- Any significant financial interest of the investigator that would reasonably appear to be affected by activities funded, or proposed for funding, by an external sponsor; or
- Any significant financial interest of the investigator in an entity whose financial interest would reasonably appear to be affected by activities funded, or proposed for funding, by an external sponsor.
To avoid any appearance of a conflict of interest, an investigator may wish to disclose other interests. Timely disclosure is a key factor in protecting one’s reputation and career from potentially embarrassing or harmful allegations.
In the process of institutional decision-making, any disclosed significant financial interest including confidential documentation, may be referred by the vice president of administrative services to the affected deans, department chairs and directors as well as other college administrators, pertinent advisory committees, and legal counsel. Confidential information will not be released by the college to other parties except as required under state laws or federal requirements.
Any significant financial interest must be disclosed at the time a proposal is submitted. These financial disclosures must be updated by investigators on an annual basis during the period of the award. If a new significant financial interest arises at any time during the period after submission of the proposal through the entire period of any resulting award, the filing of a new disclosure form is required.
Whenever an investigator has a conflict of interest to report, he/she shall complete a significant financial interest disclosure form and attach all pertinent supporting documentation related to the significant financial interest disclosed. The completed disclosure form must be SUBMITTED WITH THE PROPOSAL AND THE SIGNATURE APPROVAL FOR PROPOSED GRANTS AND CONTRACTS FROM to the vice president of administrative services. The supporting documentation that identifies the entity(ies) involved and the nature and amount of the interest is recognized to be sensitive. It should be placed in an envelope marked confidential addressed to the vice president of administrative services. After the proposal has been transmitted to the sponsor, the vice president of administrative services will review the confidential material.
The vice president of administrative services, or his/her designee, shall conduct a review of the disclosure form to confirm that the disclosed significant financial interest could affect the design, conduct, or reporting or research or activity under the proposed sponsored project. If the determination is made that there may be a conflict of interest, then the vice president of administrative services will confer with the president regarding the disclosure form and any confidential supporting documentation as soon as possible after the proposal is transmitted to the sponsor. Through this joint review, the vice president of administrative services and the president shall determine what conditions or restrictions, if any, should be imposed by the college to resolve potential conflicts of interest arising from the disclosed significant financial interest.
If requested by the vice president of administrative services, the investigator, in cooperation with his/her division dean, shall develop and present to the vice president of administrative services a conflict of interest resolution plan that proposes steps to be taken to manage, reduce, or eliminate any actual or potential conflict of interest presented by a significant financial interest. The resolution plan should include provision for:
- public disclosure of significant financial interests;
- review of project protocol by independent reviewers; and
- monitoring of project by independent reviewers.
The vice president of administrative services shall review the resolution plan, and either approve it as submitted or add conditions or restrictions that might include the following:
- modification of the project plan;
- disqualification from participation in all or a portion of the project funded;
- divestiture of the significant financial interest; or
- severance of relationships that create conflicts.
If the vice president of administrative services, in consultation with the president, determines that imposing conditions or restrictions would be ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by the public’s interest in educational progress or technology transfer, then the vice president of administrative services may allow the project to go forward without imposing conditions or restrictions, provided that this action is consistent with applicable federal rules.
The approved resolution plan shall be incorporated into a memorandum of understanding (MOU) that details the conditions or restrictions to be applied in the conduct of the project, or in the relationship with the entity in which a significant financial interest has been disclosed. The MOU shall be signed by the investigator, and the investigator’s OUA and dean. Any identified conflict of interest must be eliminated or made subject to a plan for satisfactory management PRIOR TO THE EXPENDITURE OF ANY FUNDS UNDER THE AWARD.
Whenever an investigator has violated this policy, or the terms of an MOU, the vice president of administrative services, in consultation with the president, shall recommend appropriate action. The OUA and dean shall enforce any disciplinary action consistent with college rules.
Records of investigator financial disclosures and of actions taken to manage conflicts of interest shall be retained until three (3) years after the termination or completion of the award to which they relate, or until the resolution of any outstanding issues involving those records, whichever is longer.
Bellevue College subcontractors funded from NSF awards to Bellevue College must provide appropriate assurances to the vice president of administrative services that they have the equivalent of these policies and procedures in place before Bellevue College approves and transmits its proposal including the subcontract.
This is not the only college policy governing conflict of interest, and an employee may have different or additional obligations under the state ethics law. All outside professional work for compensation and personal involvement with commercial entities must be disclosed and approved in advance.
Instructions and form available from administrative services.
Conflict of interest
- occurs when there is a divergence between an individual’s private interest and his/her professional obligations to the college such that an independent observer might reasonable question whether the individual’s professional actions or decisions are distorted by considerations of personal gain.
- means the principal investigator, co-principal investigators, and any other person who is responsible for the design, conduct, or reporting of research or educational activities funded, or proposed for funding, by an external sponsor. The term also includes the Investigator’s spouse and dependent children.
Significant financial interest
- means anything of monetary value including, 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)
- intellectual property rights (e.g., patents, copyrights, and royalties from those rights).
The term does not include:
- salary, royalties, or other remuneration from the college
- income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities
- income from service on advisory committees or review panels for public or nonprofit entities
- an equity interest that, when aggregated for the Investigator and the Investigator’s spouse and dependent children, meets both of the following tests: (a) does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and (b) does not represent more that a 5% ownership interest
- salary, royalties or other payments from entities other than the college that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the next twelve month period
Revisions 5/10/2005; 5/21/2009; 9/11/2012