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9.15 / Conflict of Interest Reporting Procedures

Wichita State University maintains and enforces a written conflict of interest policy1 that complies with federal policies (National Science Foundation's Investigator Financial Disclosure Policy and Public Health Service's Objectivity in Research) and is consistent with Board of Regents policy. The University has a responsibility to manage, reduce, or eliminate any real or apparent conflicts of financial interest or time that may arise due to the activities of a faculty or staff member. Therefore, the University requires that such individuals disclose any significant interest that would reasonably appear to be related to their research, teaching, or service assignments, and emphasizes that disclosure will protect professional reputations and careers from potentially harmful allegations of misconduct.

1 Section 3.04, Commitment of Time, Conflict of Interest, Consulting and Other Employment 

All full- and part-time faculty and unclassified staff are required to report annually whether or not they have conflicts of interest and must update the report if their circumstances change with regard to such conflicts between annual disclosures. Conflicts of financial interest must be reported for all members of the immediate family and personal household. Faculty and unclassified staff who make application for external support for their research, educational, or service projects will be required to specify on the University Proposal Routing Form that they have read the conflict of interest policy and have filed a disclosure report before their application is sent to the potential sponsor.

Procedures:
Copies of the University conflict of interest policy will be mailed to all full- and part-time faculty and unclassified staff by the Office of Research and Technology Transfer (RTT). Additional copies of the policy may be obtained at any time of the year from RTT.

Based upon a review of the policy, their University assignments, time commitments, and financial interests, faculty and staff must determine if real or apparent conflicts exist, and if so, must disclose in full the information that may affect the fulfillment of their University responsibilities. Appropriate forms will be supplied to faculty and staff for this report once a year, and ad hoc conflicts must be reported as soon as such situations become known.

All completed report forms, whether conflicts of interest exist or not, are to be submitted first to the department chair or unit head of the faculty/staff member, who after appropriate notice of any conflicts reported, will forward all report forms to the dean or director. Working with the faculty or staff member, the chair and the dean/director will address conflicts of time commitment relative to the employee's assignment. The dean/director will forward all report forms to the Vice President for Research and Technology Transfer or official designee, who shall conduct an initial review of financial disclosures and refer all reports to the Conflict of Interest Review Committee (CIRC), a University level committee, for identification of conflicts of interest. CIRC shall consist of at least four members representing a cross-section of academic and employment interests appointed by the Faculty Senate and the Unclassified Professional Senate, and shall be convened and facilitated by the Vice President for Research and Technology Transfer.

If the CIRC determines that a significant financial interest could directly affect the design, conduct, or reporting of a sponsored project, or other research, educational, or service activities, then the committee will recommend to the Vice President for Research and Technology Transfer conditions or restrictions to be imposed by the institution to manage, reduce, or eliminate actual or potential conflicts of interest that arise from the disclosure.

The faculty/staff member may develop and present to the CIRC a resolution plan to manage, reduce, or eliminate any actual or potential conflict of interest. The CIRC may recommend this plan to the Vice President for Research and Technology Transfer or develop its own plan. In either case, the recommendation may include conditions such as: public disclosure of significant financial interest; review of research protocol by independent reviewers; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in all or a portion of the research funded; divestiture of significant financial interests; or severance of relationships that create actual or potential conflicts of interest.

The Vice President for Research and Technology Transfer shall make the final decision regarding resolution, and the approved resolution plan shall be included in a Memorandum of Understanding between Wichita State University and the faculty or staff member. The memorandum shall be signed by the faculty/staff member, the department chair or unit head, and the Vice President for Research and Technology Transfer. If agreement cannot be reached on the resolution of a conflict of interest, the aggrieved parties may pursue a grievance following the procedures outlined in Resolution of Internal Disputes, Section 5.06 of this manual.

Records of financial disclosure and of actions taken to manage actual or potential conflicts of interest shall be retained by the Office of Research and Technology Transfer for three years. Disclosures, CIRC deliberations and recommendations, and resolutions of conflicts of interest are all confidential.

If the conflict of interest policy or procedures are violated by faculty or staff members, these individuals will lose the right to submit internal and external grant applications until they comply. In addition, the CIRC may recommend to the Vice President for Research and Technology Transfer disciplinary actions ranging from a public letter of reprimand to dismissal and termination of employment.

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