COI Disclosure | Office of the Vice Provost for Research

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Federal regulations and university policy outline conflict of interest disclosure requirements for faculty and staff involved in the design, conduct, or reporting of research. Completion of required forms allow WWU to determine whether a Significant Interest constitutes a conflict of interest and requires a management plan.

WWU policy POL-U20.17 Disclosing Conflict of Interest for Sponsored Programs and Technology Transfer Transactions requires that PIs and all personnel working on research projects disclose financial information that may reasonably be perceived to influence their work. Keep in mind that funding agencies may also require COI disclosure via a biographical sketch or other forms for current and pending (other) funding. All personnel working on research projects must complete the annual Conflict of Interest (COI) Disclosure IF they have significant financial interests (SFIs) to disclose.

When there are Significant Financial Interests (SFIs) or other potential COIs, a disclosure must be submitted for review.
Investigators are responsible for making sure that a current (no older than one year) disclosure is on file when there are SFIs to disclose.
Any updates to your disclosure, including adding or removing COIs, should be reported using the disclosure form within 30 days.

Reminder: In accordance with Section 10638(4)(a)(i-ix) of the CHIPS and Science Act of 2022, WWU expressly prohibits university employees, students, and faculty members from participation in/with malign foreign talent recruitment or malign foreign talent like recruitment programs.

How to use this page

This page is intended to be a resource for individuals to determine if they have conflicts of interest to disclose. Among many other things you will find the disclosure questions along with examples and exceptions, frequently asked questions, and examples/hypothetical situations. Please review the contents of this page before submitting a disclosure form.

Conflict of Interest Disclosure Form*

*Always return to this page to access the disclosure form link to ensure accuracy of your disclosures. We will update the form as funding agencies update their policies.

What is a Significant Financial Interest (SFI)?

Broadly speaking a significant financial interest is a financial interest that, if related to an individual's institutional responsibilities, could potentially create a conflict of interest in research or other activities. Many sponsors have more detailed definitions, consult your sponsor's conflict of interest policy for specific details.

Responsibilities by Role

The following information is an overview of key responsibilities by role. See specific WWU and sponsor policies for exactly what applies to your situation.

Investigator: The project director or principal investigator (PIs) and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of the research. PIs are responsible for identifying and reporting new Investigators and Innovators as they become known within thirty (30) days and ensuring their, and all other subordinate or direct reports, compliance with procedures outlined in this policy.

An Investigator/Innovator submits complete, accurate and timely disclosures, in accordance with this policy, of their personal financial interests and SFI as appropriate; participates in the design and implementation of conflict management plans; complies with conflict management plans and promotes open disclosure and best practices in research integrity in the performance of their University duties.

Assists in coordination of administrative components related to this policy, confirms Investigator and Innovator designations with appropriate persons/offices, provides other disclosure support as appropriate.

Ensures sufficient and appropriate internal controls are in place for the successful implementation of issued FCOI management plans or other related restrictions and conditions, with an emphasis on promoting disclosure and transparency in academic and scholarly activities.

Take such actions that it deems reasonable to audit and/or monitor compliance with conflict management plans and strategies, which may include obtaining regular reports from individuals or committees charged with oversight responsibilities in connection with conflict management.

The Vice Provost for Research is WWU's IO for research related conflict of interest and is authorized to administer and enforce this policy. Such authorization permits the IO, or their delegates, to:

Obtain and review SFI disclosures under this policy
Develop and implement conflict management strategies and documentation to reduce or eliminate identified FCOIs
Conduct any required late or retrospective reviews, including issuance of reports of findings and conclusions and development and implementation of conflict and mitigation plans
Communicate with federal and other sponsors on matters pertaining to this policy
Make recommendations to the University with respect to matters covered by this policy
Develop and implement reasonable and appropriate summary procedures for the disposition of matters involving compliance with this policy
Disallow for good cause a proposed research project or technology transfer transaction or suspend an ongoing research project or pending technology transfer transaction to prevent any probable or continued violations to this policy, or to prevent any inadvertent violations of sponsor policy, state, or federal law or regulation.

Questions to Expect in the Disclosure Form

The following categories of questions represent what you will be asked when completing the disclosure form. Expand the accordion to see exact questions. Please review these along with the other information on this page to determine if you need to submit a disclosure form for review.

Helpful Tip: While you complete the disclosure form, we recommend having this particular accordion expanded to view examples and exceptions for the questions.

The first section of the disclosure form after the initial personal information (name, contact info, department, college, etc.) will ask questions about your current and future grant/sponsored project plans. Depending on your answers staff from the Office of the Vice Provost for Research (Research & Sponsored Programs and Research Integrity & Compliance) may follow up with you separately with additional questions based on your sponsor's specific COI policies and reporting requirements.

Questions about your grants/sponsored projects (exact wording and numbering is subject to change)

Are you currently a Principal Investigator (PI) or a co-PI on a grant or sponsored project, or an Inventor involved in a technology transfer transaction?
- The project director or principal investigator (PI)/co-PI and any other person, regardless of title or position, who is responsible for the design, control or reporting of the sponsored project.
- Sponsored projects are funded research, instruction, training, testing, service, or other scholarly activities in which a formal written agreement, i.e., a grant, cooperative agreement, or contract is entered into between WWU and the sponsor.
- Technology transactions are any arrangement through which the University conveys, licenses, assigns or otherwise provide University Intellectual Property, research results, proprietary materials, or specialized expertise to an external individual, company, or organization for the purpose of development, commercialization, public use, or further application.
Please provide grant/sponsored project details including the WWU assigned grant number (or Proposal Routing Form "PRF" number, if you are including the PRF number indicate that it is from a PRF) the grant name, the grant program, the funding agency, and when the grant is active (specific dates).
Do you plan to apply for a grant or sponsored program funding in the next 12 months?
- Reminders: All external funding proposals must exit WWU through the Research and Sponsored Programs (RSP) Office. See the RSP website for more information about Proposal Preparation. All application materials must be finalized and reviewed by RSP pre-award staff at least 5 business days in advance of the sponsor's submission deadline or the preferred submission deadline.
Please provide details including when you plan to apply, the grant name, grant program, and funding agency/sponsor.

A financial conflict of interest is any financial interest, direct or indirect, or engagement in a business or transaction or professional activity, or possess or acquire an obligation of any nature, that is in conflict with the proper discharge of one's duties. FCOIs may include the real or perceived conflicts of interest for family members, as well as a commitment or obligation to consulting, research, or other scholarly activities requiring the individual to perform work or activities during the time that the individual is expected to perform services for the University (RCW 42.52).

FCOI Related WWU Policies

POL-U20.17 Disclosing Conflict of Interest for Sponsored Programs and Technology Transfer Transactions: https://policy.wwu.edu/POL-U20.17-Disclosing-Conflict-of-Interest-for-Sponsored-Programs-and-Technology-Transfer-Transactions
POL-U4520.03 Patent and Copyright Policy: https://policy.wwu.edu/POL-U4520.03-Patent-and-Copyright-Policy
POL-U5348.01 Purchasing Goods and Services: https://policy.wwu.edu/POL-U5348.01-Purchasing-Goods-and-Services
POL-U5348.05 Authorizing Agreements and Contracts: https://policy.wwu.edu/POL-U5348.05-Authorizing-Agreements-and-Contracts
POL-U5348.09 Paying Honoraria or Stipends to Non-Employees: https://policy.wwu.edu/POL-U5348.09-Paying-Honoraria-or-Stipends-to-Non-Employees

Questions about FCOIs (applies to all projects, exact wording and numbering is subject to change)

Do you hold any intellectual property (IP) rights or have a financial interest derived from IP that may present a conflict of interest for your sponsored project?
- This can include royalties, milestones, and option fees paid by a third party.
- Exceptions: Any royalties, licensing fees, or other income received from WWU from patents, copyrights, or other intellectual property.
Please provide details about your intellectual property. E.g. type, patent # or provisional patent #, brief description.
Do you have any gifts, grants, and/or contracts that are not managed by WWU to disclose? This can include gifts or in-kind contributions from external entities or persons made directly to, or delivered directly to, you in support of your professional, scientific, research, or academic activity.
- Exceptions:
  - Effort (paid or unpaid) on a research or sponsored project managed by WWU (e.g., sponsored research, WWU-funded research)
  - Grants, gifts, discretionary funds, or other funding received through WWU
  - Gifts made to WWU
Please provide further details about your gifts, grants, and/or contracts that are not managed by WWU. Details should include company/agency name, type, amount, date received, and reason for receiving.
Do you and or your immediate family (spouse/partner and dependent children) have any Ownership Equities that are more than 5%? This can include more than 5% ownership (e.g., stock, stock options, or other ownership interests) in a company. Please provide more information about your ownership equities that are more than 5%.
- Exceptions:
  - Any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program (SBIR) or Small Business Technology Transfer Program (STTR)
  - Mutual funds, retirement funds, and similar investments where you do not control the investment decisions

This section of the disclosure applies to NSF projects only and are based on the disclosure requirements for awardees outlined in the NSF Proposal and Award Policies & Procedure Guide (PAPPG), Chapter IX: Recipient Standards.

The following questions pertain to NSF PIs and will ask about significant financial interests (SFIs). Note: Some of NSF's defined SFIs also apply to other types of projects and therefore may appear in different sections of this form or may be covered by other WWU policies.

From the PAPPG: The term “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 interest (e.g., stocks, stock options, private equity, or other ownership interests); venture or other capital financing, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights). The term does not include:

salary, royalties, or other remuneration from WWU
any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program (SBIR) or Small Business Technology Transfer Program (STTR)
income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities (not WWU)
- WWU Policies
  - POL-U1500.09 Faculty Policy on Outside Work: https://policy.wwu.edu/POL-U1500.09-Faculty-Policy-on-Outside-Work
  - POL-U30.48 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities: https://policy.wwu.edu/POL-U5400.17-Professional-Staff-Policy-on-Consulting-and-Other-Outside-Compensated-Professional-Activities
income from service on advisory committees or review panels for public or nonprofit entities (not WWU)
- WWU Policies
  - POL-U1500.09 Faculty Policy on Outside Work: https://policy.wwu.edu/POL-U1500.09-Faculty-Policy-on-Outside-Work
  - POL-U30.48 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities: https://policy.wwu.edu/POL-U5400.17-Professional-Staff-Policy-on-Consulting-and-Other-Outside-Compensated-Professional-Activities
an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests:
- i. does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value
- ii. does not represent more than a 5% ownership interest in any single entity
salary, royalties, or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.

Questions about FCOIs for NSF Projects (applies to all projects, exact wording and numbering is subject to change)

Do you plan to apply for any National Science Foundation (NSF) grants/sponsored programs in the next 12 months?
Please provide more information about what NSF grant(s)/sponsored programs you are planning to apply for in the next 12 months. Details should include your role on the project, name of grant, name of grant program (no abbreviations please), date of when you plan to apply, and dates of when grant will be active.
Are you currently a part of any National Science Foundation (NSF) grants/sponsored programs? If yes, please provide details about your current NSF grant(s)/sponsored project(s). Details should include your role on the project, name of grant, name of grant program (no abbreviations please), grant number (or WWU Proposal Routing Form "PRF" #), and dates of grant.
Do you and or your immediate family (spouse/partner and dependent children) have any equities that exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value? If yes, please provide more information about your equities exceeding $10,000. Details provided should include company name, amount, and dates.
Have you or your immediate family (spouse/partner and dependent children) collected salary, royalties, or other payments that, when aggregated for the PI and the PI’s immediate family, are expected to exceed $10,000 during the last 12 months? If yes, Please provide more information about the salary, royalties, or other payments expected to exceed $10,000.Details should include type of payment, company name, amount, and reason for payment.

This section of the disclosure applies to PHS projects only and are based on the disclosure requirements for awardees outlined in 42 CFR Part 50, Subpart F, "Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought."

The following questions pertain to PHS PIs and will ask about significant financial interests (SFIs), reimbursed or sponsored travel, and foreign financial interests and payments. Note: Some of PHS's defined SFIs also apply to other types of projects and therefore may appear in different sections of this form.

From 42 CFR Part 50, Subpart F: A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's institutional responsibilities:

i. With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value
ii. With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator's spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest)
iii. Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.

The PHS comprises all agency divisions of Health and Human Services including:

Administration for Children and Families (ACF)
Administration on Aging (AoA)
Agency for Healthcare Research and Quality (AHRQ)
Agency for Toxic Substances and Disease Registry (ATSDR)
Centers for Disease Control and Prevention (CDC)
Centers for Medicare & Medicaid Services (CMS)
Federal Occupational Health (FOH)
Food and Drug Administration (FDA)
Health Resources and Services Administration (HRSA)
Indian health Service (HIS)
National Institutes of Health (NIH)
Substance Abuse and Mental Health Services Administration (SAMHSA)
Public Health Service Commissioned Corps

Questions about FCOIs for PHS Projects (applies to all projects, exact wording and numbering is subject to change)

Do you currently hold any Public Health Service (PHS) grants? This includes National Institute of Health (NIH) grants. If yes, please provide more information about your current PHS grant(s)/sponsored project(s). Details should include your role on the project, name of grant, name of grant program (no abbreviations please), grant number (or WWU Proposal Routing Form "PRF" #), and dates of grant.
Do you plan to apply for any Public Health Service (PHS) including National Institute of Health (NIH) grants/sponsored projects in the next 12 months? If yes, please provide more information about the PHS grant(s)/sponsored project(s) you plan to apply for in the next 12 months. Details should include your role on the project, name of grant, name of grant program (no abbreviations please), PHS agency name, application date, and estimated dates when the grant will be active.
Do you or your immediate family (spouse/family and dependent children) have any renumeration coming from publicly traded entities in the last 12 months that when aggregated exceeds $5,000? If yes, please provide more information about the renumeration you/immediate family have received from publicly traded entities in the in the last 12 months that exceeds $5,000. Details should include company name, amount, and dates.
- This can include:
  - Salary and any payment for services otherwise not identified as salary. Examples: Consulting fees, honoraria, paid authorship, etc.
  - Equity interest including any stock, stock options, or other ownership interest as determined through reference to public prices or other reasonable measures of fair market value
- Exceptions: Income from investment vehicles such as mutual funds and retirement accounts that you do not directly control the investment decisions made by these vehicles.
Do you or your immediate family (spouse/family and dependent children) have any renumeration coming from non-publicly traded entities in the last 12 months that when aggregated exceeds $5,000? If yes, please provide more information about the renumeration you/immediate family have received from non-publicly traded entities in the in the last 12 months that exceeds $5,000. Details should include company name, amount, and dates.
- This can include:
  - Salary and any payment for services otherwise not identified as salary. Examples: Consulting fees, honoraria, paid authorship, etc.
  - Equity interest including any stock, stock options, or other ownership interest as determined through reference to public prices or other reasonable measures of fair market value
- Exceptions:
  - Salary, royalties, or other remuneration paid by WWU (this includes intellectual property renumeration)
  - Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency located in the United States, a United States Institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a United States Institution of higher education
  - Income from service on advisory committees or review panels for a federal, state, or local government agency located in the United States, a United States Institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a United States Institution of higher education
Do you have any income from foreign financial interests that exceeds $5,000? If yes, please provide more information about income from foreign financial interests that exceeds $5,000. Details should include type of financial interest, source of financial interest, reason, amount, and dates.
- This includes income from:
  - Seminars, lectures, or teaching engagements
  - Service on advisory committees or review panes
  - Reimbursement for sponsored travel
Have you received any payments from any foreign entity that exceeds $5,000? If yes, please provide more information about foreign entity payments you received greater than $5,000. Details should include name of entity, why payment was received, amount, and date.
- This includes payments from:
  - Foreign institutions of higher education
  - Foreign government (local, provincial, or equivalents governments of another country)

A conflict of commitment is a situation in which an individual accepts or incurs conflicting obligations between or among multiple employers or other entities. Many organizational policies define conflicts of commitment as conflicting commitments of time and effort, including obligations to dedicate time in excess of organizational or research agency policies or commitments. Other types of conflicting obligations, including obligations to improperly share information with, or to withhold information from, an employer or research agency, can also threaten research security and integrity, and are an element of a broader concept of conflicts of commitment used in this disclosure form.

COC Examples for Sponsored Projects

Outside of WWU....

Paid or unpaid appointments or employment
Paid or unpaid advisory or service positions
Research, editorial, or writing positions
Leadership roles
Conference attendance or presentation compensation, presentation compensation, or other honoraria
Participate in activities related to your academic, scientific expertise or licensed profession
Participation in a foreign talent program (see the Malign Foreign Talent Recruitment Programs page for more detailed information)
- This can include participation in a foreign government talent recruitment or similar program for a company, university, government or other entity, including in exchange for support in the form of research funding, lab facilities or research staff, and/or in connection with the receipt of an honorarium, monetary prize or other compensation.
International advisory and/or service role (current or past appointments not part of a WWU agreement)
International research role (not pursuant to a WWU agreement with foreign entity)
International travel (paid or reimbursed by foreign entity)
As part of your WWU employment....
- Travel related to your WWU responsibilities
- Participation in a foreign talent program (see above link for more information)

WWU Conflict of Commitment Policies

For Faculty: POL-U1500.09 Faculty Policy on Outside Work
For Professional Staff: POL-U30.48 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities

Certifications about COCs for ALL Projects: The following questions apply to all projects. The exact wording and numbering are subject to change. Examples of certification answers are included as bullet points at the end of each certification statement section.

Malign foreign talent recruitment programs (MFTRPs) are programs, positions or activities sponsored by a country of concern (defined as the People's Republic of China including Hong Kong and Macau, the Democratic People's Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country determined to be a country of concern by the Secretary of State) or by certain academic institutions. It is not illegal to engage in malign foreign talent recruitment programs. However, the Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act of 2022 prohibits federal funding agencies from issuing awards to anyone who participates in a malign program.
- MFTRPs include one or more of the following indicators:
  - Engagement in the unauthorized transfer of intellectual property or other nonpublic information.
  - Recruiting trainees or researchers to enroll in such program, position, or activity.
  - Establishment of a laboratory, employment or appointment in a foreign country in violation of the terms and conditions of a U.S. federally funded research award.
  - Inability to terminate program contract or agreement.
  - Overcapacity, overlap or duplication.
  - Research funding from the foreign institution’s government.
  - Omission of U.S. home institution and/or funding agency acknowledgement.
  - Nondisclosure of program participation.
  - Conflict of interest and/or conflict of commitment.
- Certification Statements (select one)
  - I certify that I have not and am not currently participating in or have participated in the past in any Malign Foreign Talent Recruitment Programs.
  - I have a concern about possible participation in Malign Foreign Talent Recruitment Programs and I will contact researchintegrity@wwu.edu ASAP to discuss further and determine next steps.
For Faculty positions only: Please review POL-U1500.09 Faculty Policy on Outside Work.
- Certification Statements (select one)
  - I certify that I am aware per POL-U1500.09 that all outside work must be disclosed, upon initial contracting and once per subsequent academic year thereafter, to the Department Chair and approved by the College Dean or equivalent administrator. Outside work by a College Dean must be reported to the Provost.
  - I need further clarification about how this related to grants and sponsored projects. I will contact researchintegrity@wwu.edu to ask my questions.
For Professional Staff positions only: Please review POL-U30.48 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities.
- Certification Statements (select one)
  - I certify that I am aware per POL-U30.48 that all outside work must be reported annually by the staff member to the Unit Head (or comparable unit administrator).
  - I need further clarification about how this related to grants and sponsored projects. I will contact researchintegrity@wwu.edu to ask my questions.

Several other WWU policies include COI clauses in their policy statements. Excerpts of the sponsored project applicable sections are included in the certification statements.

Please review POL-U30.51 Employing Family Members And Significant Others. Summary of key points for certification are included below.
- Applies to all non-faculty employment positions including student employment. Faculty positions are addressed in the United Faculty of Western Washington University Agreement.
- Policy Statement #4: Employees and Applicants Must Disclose Relationship When Applicable
  - Job applicants must disclose a family or significant other relationship on their employment application. Employees must disclose a family or significant other relationship to Human Resources and their department chair or director when a potential conflict of interest has occurred or may occur because:
- A family member or significant other has applied or will apply for a position, or
- Their personal circumstances have or will change following employment (e.g. marry while employed or become romantically or financially involved with another employee). See POL-U1600.06 Prohibiting Consensual Intimate Personal Relationships Between Supervisors and Supervisees.
- If, in the opinion of the AVP, a conflict of interest arises as a result of the relationship, efforts to implement sufficient controls will be made at the earliest practicable time following consultation with the appropriate vice president(s) or the President when applicable.
- Certification Statement: I certify that I am aware per POL-U30.31 of the requirement to report conflicts of interest related to the employment of family members and significant others.
Please review POL-U30.31 Authorizing Agreements and Contracts. Summary of key points for certification are included below
- Applies to all contracts regardless of funding source for sponsored projects.
- Policy Statement #3: Employees Must Comply with State Ethics Laws
  - Conflicts of Interest: No employee may have an interest (financial or otherwise, direct or indirect) or engage in a business or transaction or professional activity or incur an obligation that is in conflict with the proper discharge of the employee’s official duties (RCW 42.52.020). This includes having or acquiring a financial or other interest in a contract, sale, lease, purchase or grant that is under the employee’s authority or supervision (RCW 42.52.030). Western recognizes that not all relationships are a conflict of interest. However, it is incumbent on the employee to promptly report what may be potentially perceived as a conflict of interest to the University Ethics Officer (Director of Internal Audit or current designee) for review and documentation of good faith efforts to disclose and engage in ethical agreements.
  - Gifts: Employees who seek to acquire goods or services or who participate in those contractual matters are subject to state requirements on accepting gifts (RCW 42.52.150). In addition, any entity or individual who seeks or may seek a contract with the University are also subject to the state requirements on accepting and giving gifts. Employees are encouraged to contact the University Ethics Officer (Internal Auditor) regarding any questions or concerns about gifts.
- Certification Statement: I certify that I am aware per POL-U30.31 of the requirement to report conflicts of interest related to agreements and contracts.
Please review POL-U30.32 Paying Honoraria or Stipends to Non-Employees. Summary of key points for certification are included below.
- Applies to offering non-employees an honorarium or stipend. Students and employees are not eligible to receive honoraria from the University.
- Policy statement #3: Potential Conflicts of Interest to be Reviewed
  - No University employee may be beneficially interested, directly or indirectly, in an honorarium or stipend arrangement involving the University that may be made by or through the employee, or is under the supervision the employee, in whole or in part, or accept, directly or indirectly, any compensation, gratuity, or reward from any other person beneficially interested in the contract, sale, lease, purchase, or grant.
  - Western recognizes that not all relationships are a conflict of interest. However, it is required that employees involved in an honorarium arrangement and approval process promptly report what may be potentially perceived as a conflict of interest to the University Ethics Officer for review and/or assistance to mitigate the potential conflict.
- Certification Statement: I certify that I am aware per POL-U30.32 of the requirement to report conflicts of interest related to paying honoraria to non-employees.

Common Disclosure Policies, Criteria, and Definitions

Below you will find the COI disclosure requirements for National Science Foundation (NSF) and Public Health Service (PHS) projects along with the requirements for all WWU projects regardless of funding source.

NSF encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures but recognizes that such interactions carry with them an increased risk of conflicts of interest. Chapter IX.A of the Proposal and Award Policies and Procedures Guide (NSF PAPPG) contains NSF's policy on conflicts of interest.

Each investigator disclose all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children): (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities.

NSF Definition of a Significant Financial Interest (SFI)

NSF defines an SFI as anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).

The term does not include:

salary, royalties or other remuneration from the proposing organization
any ownership interests in the organization, if the organization is an applicant under the Small Business Innovation Research Program (SBIR) or Small Business Technology Transfer Program (STTR)
income from seminars, lectures, or teaching engagements sponsored by public or non-profit 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: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity
salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period

A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of NSF-funded research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to:

public disclosure of significant financial interests
monitoring of research by independent reviewers
modification of the research plan
disqualification from participation in the portion of the NSF-funded research that would be affected by significant financial interests
divestiture of significant financial interests
severance of relationships that create conflicts

If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.

Organizations must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any NSF action involving those records, whichever is longer.

The Department of Health and Human Services (HHS) regulation 42 CFR Part 50 Subpart F, Promoting Objectivity in Research (FCOI regulation), establishes standards that provide a reasonable expectation that the design, conduct, or reporting of NIH-funded research (grants and cooperative agreements) will be free from bias resulting from any Investigator’s conflicting financial interest. NIH requires recipient institutions and their investigators (except Phase I SBIR/STTR applicants and recipients) to fully comply with all FCOI requirements. If the Institution carries out the NIH-funded research through a subrecipient (e.g., subcontractors or consortium members), the Institution must take reasonable steps to ensure that any subrecipient Investigator complies with FCOI requirements.

Investigator: The PD/PI and any other person, regardless of title or position who is responsible for the design, conduct, or reporting of NIH-funded research, or proposed for such funding, and which may include for example, collaborators or consultants. Includes investigators who plan to participate in or who participate in NIH-funded research.

PHS Definition of a Significant Financial Interest (SFI)

A financial conflict of interest exists when the institution's designated official(s) reasonably determines that an investigator's significant financial interest (SFI) could directly and significantly affect the design, conduct, or reporting of the NIH-funded research. The institution is required to review each Investigator SFI disclosure to determine if a SFI is related to the NIH-supported research (i.e., could the SFI be affected by the research or is the SFI in an entity whose financial interest could be affected by the research) and could directly and significantly affect the design, conduct, or reporting of the NIH-funded research.

A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's institutional responsibilities:

With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value
With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator's spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest)
Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests
Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities; provided, however, that this disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education. The Institution's FCOI policy will specify the details of this disclosure, which will include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration. In accordance with the Institution's FCOI policy, the institutional official(s) will determine if further information is needed, including a determination or disclosure of monetary value, in order to determine whether the travel constitutes an FCOI with the PHS-funded research.
The term significant financial interest does not include the following types of financial interests:
- salary, royalties, or other remuneration paid by the Institution to the Investigator if the Investigator is currently employed or otherwise appointed by the Institution, including intellectual property rights assigned to the Institution and agreements to share in royalties related to such rights
- any ownership interest in the Institution held by the Investigator, if the Institution is a commercial or for-profit organization
- income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles
- income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education
- income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education

WWU supported projects include research activities supported with university funds (e.g. department budget, RSP internal grants, other WWU internal grants, etc.). Refer to the state laws and policies below for definitions and thresholds.

Washington State Law: Chapter 42.52 RCW: Ethics in Public Service

WWU Policies

Frequently Asked Questions

The following FAQ is meant to address common questions about WWU policies and the COI disclosure process.

All personnel working on research projects must complete the annual Conflict of Interest (COI) Attestation. These individuals include:

All WWU employees participating in externally funded research
All individuals participating in research under the auspices of WWU, regardless of compensation (this includes research affiliates and research associates)

Conflicts of interest can occur when members of the University community are in a position to gain, or appear to gain, financial advantage or personal benefit (broadly construed) arising from their University positions, either through outside professional activities or through their research, administrative, or educational actions or decisions at the University.

Faculty: A faculty member providing professional expert advice related to their scholarly, technological, scientific, and creative expertise to outside entities or individuals, including any other outside work, consulting, or self-employment activity performed by a faculty member, whether compensated or not, which is entirely outside of their official University duties. POL-U1500.09 Faculty Policy on Outside Work

Professional Staff: Outside compensated professional activities for the purpose of this policy includes activities for other organizations in the areas of professional competence for which the staff member is employed by Western Washington University, such as consulting, advising, research, demonstrating, or teaching. Outside profit-making business activities engaged in for personal monetary gain which are not related to the area of professional competence for which the staff member is employed by the University are covered under the state ethics laws. Outside work must be conducted in compliance with the University’s policy on Using University Resources. POL-U5400.17 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities

Research Personnel are required to disclose COIs annually. Any updates to your dislcosures, including adding or removing COIs, should be reported using the disclosure form within 30 days.

See "Questions to Expect on the Disclosure Form" for exact details.

The Institutional Official (Vice Provost for Research) or their appointed delegate will review disclosures.

No. All research personnel must submit their own attestation.

See WWU policies on Conflicts of Commitment for details.

For Faculty only: POL-U1500.09 Faculty Policy on Outside Work
For Professional Staff only: POL-U30.48 Professional Staff Policy on Consulting and Other Outside Compensated Professional Activities

No, external interests are not automatically considered a conflict of interest.

If you have reported disclosures, then your responses will be reviewed to determine if a possible conflict of interest exists. If it is determined that your conflict requires management, then you will be contacted if further information is required and a management plan will be developed. You will have to agree and sign off on the management plan before proposals can be submitted or research can resume.

Review "Questions to Expect on the Disclosure form" and contact researchintegrity@wwu.edu if you have further questions.

Examples and Hypothetical Situations

The following information is intended to provide a brief overview of hypothetical situations that may or may not require COI disclosure. If you have any questions, please contact us. Examples of outside interests/activities that may need to be disclosed can include (but are not limited to):

Financial Conflicts of Interest

Consulting engagements
External paid appointments
Intellectual property
Ownership in an outside entity (e.g. stock/equity options)
Travel paid or reimbursed by a non-US entity
Accepting gratuities or special favors from companies doing business or sponsoring one's research at the University
Accepting over-scale honoraria for lectures at companies whose economic or political interests are affected by an investigator's research
Performing evaluative research for a company in which the investigator has a financial interest
Using students to perform services for a company in which you have a financial interest
Providing privileged access to information developed with University or independent sponsorship to another entity in which you have a financial interest
Negotiating on behalf of the University for the purchase of materials from a company in which you have a financial interest
Directly influencing the negotiation of contracts, including research contracts or licensing contracts, between the University and a company in which you have a financial interest
Providing or receiving financial bonuses for meeting subject recruitment targets or achieving stated results
A faculty member is an owner, manager or officer of a company that does business with the university.
A staff member is to take part in the evaluation and selection of a vendor from multiple bidders. One of the bidding companies is operated by the staff member’s wife.
A staff member would like to hire their spouse as a consultant to the University.

Conflicts of Commitment

Holding office or membership on a board or committee of an entity supporting your University research
External unpaid appointments
A Faculty member provides consulting for a private company related to using technology and developing products associated with their research at WWU.
A faculty member would like to use WWU laboratory space and resources for consulting purposes.
A faculty member is offered a position on a scientific board of a company that has research contracts with the faculty member’s department.

Hypothetical Situations

Situation: Dr. Greene has been invited to give a presentation at an international conference regarding their recently published research. In their presentation Dr. Green credits their collaborators and funding resources. They receive an honorarium from the conference organizers.

Next Steps: By providing the conference attendees and the public with a full understanding of her collaborators and financial support Dr. Greene acceptance of the honorarium is not a COI because it is not a "quid pro quo" exchange of knowledge for compensation. Their results are already published, and the purpose of the speaking engagement at the conference is to share the results with the academic community. The honorarium does not contravene this purpose.

Situation: Dr. Jay receives an exciting research proposition from a foreign agency involving a new project.

Next Steps: Before moving forward, Dr. Jay should disclose the opportunity via the disclosure form to ensure this new commitment does not conflict with her existing obligations. Remember, not all conflicts of interest are disqualifying, so long as risks are disclosed and managed appropriately.

Situation: Dr. Hernandez, a well-respected researcher in her field, has been approached by a foreign organization who is offering substantial financial support for his ongoing research project. The organization's website contains no information about its own funding sources and does not disclosure this information in communications with Dr. Hernandez. In exchange for its financial support, this organization requires exclusive rights to Dr. Hernandez's research findings and tells her to not inform WWU about the partnership.

Next Steps: It is not clear where the foreign organization receives its funds, which may obscure nefarious connections and could be considered to be a type of Malign Foreign Talent Recruitment Program. By asking Dr. Hernandez to not disclosure her funding sources and accompanying obligations the foreign organization is placing her in a compromised position by violating WA state law and WWU policies (and potentially other funding agency COI disclosure policies). Dr. Hernandez should immediately report this offer to WWU Research Integrity and Compliance staff.

Situation: Dr. O'Malley collaborates with a research team that includes members in many different countries. They maintain a joint secure data sharing platform to ensure that all parties in the project are able to have access to the research progress and data. Any published work cites all contributors. All institutions are informed of this arrangement.

Next Steps: This collaboration reinforces values of openness and transparency by providing all research participants and institutions with full and open access to the research data. Each institution is aware of the collaboration and has an opportunity to identify potential COIs of interest or commitment should they arise.

Situation: Dr. Lee has applied for an external grant to support a new direction in their research. As a part of the proposed budget Dr. Lee has identified their partner as a consultant on the project and has not previously disclosed their relationship.

Next Steps: Hiring a family member is in violation several WWU policies unless specific actions are taken.

POL-U30.31 Authorizing Agreements and Contracts

Policy Statement #3: Employees Must Comply with State Ethics Law.

Conflicts of Interest: No employee may have an interest (financial or otherwise, direct or indirect) or engage in a business or transaction or professional activity or incur an obligation that is in conflict with the proper discharge of the employee’s official duties (RCW 42.52.020). This includes having or acquiring a financial or other interest in a contract, sale, lease, purchase or grant that is under the employee’s authority or supervision (RCW 42.52.030). Western recognizes that not all relationships are a conflict of interest. However, it is incumbent on the employee to promptly report what may be potentially perceived as a conflict of interest to the University Ethics Officer for review and documentation of good faith efforts to disclose and engage in ethical agreements.

POL-U30.51 Employing Family Members And Significant Others

Summary of key points:

Applies to all non-faculty employment positions including student employment. Faculty positions are addressed in the United Faculty of Western Washington University Agreement.

Policy Statement #4: Employees and Applicants Must Disclose Relationship When Applicable.

Job applicants must disclose a family or significant other relationship on their employment application. Employees must disclose a family or significant other relationship to Human Resources and their department chair or director when a potential conflict of interest has occurred or may occur because:
- A family member or significant other has applied or will apply for a position, or
- Their personal circumstances have or will change following employment (e.g. marry while employed or become romantically or financially involved with another employee). See POL-U1600.06 Prohibiting Consensual Intimate Personal Relationships Between Supervisors and Supervisees.
If, in the opinion of the AVP, a conflict of interest arises as a result of the relationship, efforts to implement sufficient controls will be made at the earliest practicable time following consultation with the appropriate vice president(s) or the President when applicable.