Summary: Full-time faculty and staff of Ithaca College who propose to receive funds from an external federal or corporate source for research or materials development projects must indicate, in the process of approval, whether any conditions exist which might create an actual or apparent conflict of interest, with potential to harm the integrity of the proposed work or the reputation of the College.

A possible conflict of interest does not preclude acceptance of the grant or contract in question; but appropriate disclosures or other safeguards may need to be implemented and accepted by both the investigator and the institution. Information received on possible financial interests in a proposed project will be kept strictly confidential, except where public disclosure is a safeguard the investigator and College have agreed upon; however, records of such internal disclosure may be subject to IRS audit or court subpoenas.

Each investigator who proposes to receive a governmental or corporate grant or contract must complete and sign a form that enables the College to answer three questions:

1. Does the investigator, his or her colleagues, family, or associates have a significant financial interest that would reasonably appear to be affected by the conduct or outcome of the grant-funded activities?

2. Will the significant financial interest, if it exists, potentially affect the integrity of the project, i.e. how the project is run or what kinds of results are reported?

3. If a potential effect or the appearance of an effect on the project is present, what steps will the investigator and the College take to assure its integrity?

What Is Significant Financial Interest?

It is the ownership of 5% or more of a company or business that will potentially benefit from the work; ownership of $10,000 or more in stock, patents, or other assets that are likely to be affected by work or its results; or an income of $10,000 or more within one year to be reasonably projected through salary, royalties, or other fees. The salary that is to be drawn from the grant, contract, or fellowship itself, or from the College as recipient of funds, is exempted; so are lecture fees and consultant fees that may be drawn from non-profit entities as a result of the grant. (Ownership of over $10,000 equity representing less than 5% ownership of a listed stock company whose business might be affected by the grant outcomes need not be reported as a potential conflict.)

What Are the Ways of "Managing" Possible Conflict of Interest?

After review determines that a conflict exists, the College may require that any of a wide range of steps be taken, following discussion with the investigator. These may range from disclosure to the funder, to disclosure in public announcements, to special monitoring arrangements, to divestment of the conflicting interest. The College's purpose in management of conflict of interest will be to protect the following: its own fiscal interests and reputation; the intellectual integrity of scholarly work associated with the College; and the professional growth of faculty and staff. Steps taken to manage a conflict of interest need not be undertaken until notice of award is received, but must precede expenditure of funds.

What Procedure Will Be Followed?

Faculty or staff members applying for grants, contracts, or comparable awards through the College will sign a simple form as part of the routing process, indicating that they do or do not have a present or foreseeable "significant financial interest" related to the grant or contract. If they indicate that they do or may have such an interest, a confidential disclosure will be required for review by an administrative panel representing the Provost's Office, Academic Funding, and the College Counsel. Appropriate senior faculty members may also be impaneled if their expertise is required. If a potential conflict is present, management steps will be proposed, discussed with the investigator, and then stipulated as conditions for expenditure of the award.

The above policy refers only to externally sponsored research, materials development, training, and other types of program delivery in which funds are awarded to or handled by the College. External funding awarded directly to an investigator rather than through the College must be reported to the Provost as outside employment. The College reserves the right to require faculty or other employees to follow the procedure described above if the outside employment project substantively involves use of other College personnel or College resources other than use of the investigator's office space, office computer, and comparable standard resources provided to individual faculty members.

Maintained by Denise Vanderburgh (dvanderburgh@ithaca.edu)
Office of Academic Funding and Sponsored Programs

Last updated 1 May 2007