Bradley University Conflict of Interest Policy for Sponsored Programs

Background

All scholarly activity conducted at Bradley University must conform to the highest ethical standards and comply with federal regulations, regardless of funding source. For the University to remain eligible to receive extramural funding, we must all adhere to federal policies. Several training modules are available through the Collaborative Institutional Training Initiative (CITI) to help employees better understand these regulations. In 2024, Federal funding agencies were required to establish “a uniform set of guidelines for Federal research agencies regarding foreign talent recruitment programs.” ¹ In response to these changes, Bradley University revised its Financial Conflict of Interest policy for Sponsored Programs to ensure compliance with the changes to Federal requirements. The changes are in response to “some foreign governments’ vigorous efforts to acquire research and intellectual capital from the United States and our allies through both licit and illicit means. This includes the transfer of intellectual property in violation of U.S. export controls, and the misappropriation of research data and know-how infringing upon higher education’s values and commitment to openness, transparency, honesty, and fairness.” ²

Please Note: This policy is separate from Bradley University’s Conflict of Commitment and Conflict of Interest Policy and procedures. This policy pertains specifically to Bradley University investigators seeking and receiving external funding support for their work.

Forms and Resources

Instructions for Completing the CITI COI Course Significant Financial Interest Disclosure Form

Bradley Univeristy Policy

Before submitting a request for funding from an external entity and after receiving external funding, Bradley employees serving as sponsored program investigators MUST:

Complete CITI Conflict of Interest (COI) Course under a BU Learner Group at least once every four years.
Complete the Bradley University’s Significant Financial Interest (SFI) and Foreign Influence Disclosure Form at least once a year.
- Submit an updated Significant Financial Interest (SFI) and Foreign Influence Disclosure Form within 30 days when a new conflict of interest arises or changes occur to the previously disclosed information.
Cooperate with actions to manage any identified conflict of interest(s).

Questions and Answers

Questions on the Significant Financial Interest (SFI) and Foreign Influence Disclosure Form and the Federal statements that serve as the basis for the question. All financial interests that appear reasonably related to the Investigator's institutional responsibilities during the twelve months preceding this disclosure MUST be reported.

Did the Investigator, the Investigator's spouse, or the Investigator's dependent children receive any remuneration from a publicly traded entity and hold equity interest in the entity as of the date of disclosure that exceeds $5,000 when aggregated?
- “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;” ⁴
Did the Investigator, the Investigator's spouse, or the Investigator's dependent children receive any remuneration from a non-publicly traded entity that exceeds $5,000 when aggregated?
Does the Investigator, the Investigator's spouse, or the Investigator's dependent children hold any equity interest (e.g., stock, stock option, or other ownership interest) in a non-publicly traded entity?
- “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)” ⁴
Does the Investigator, the Investigator's spouse, or the Investigator's dependent children hold intellectual property rights and interests (e.g., patents, copyrights) that generated income related to such rights and interests? Note: Revenue from University-owned intellectual property does not need to be reported.
- “Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.” ⁴
- “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…” ⁴
Did the Investigator, the Investigator's spouse, or the Investigator's dependent children receive any reimbursed or sponsored travel related to their institutional responsibilities from an entity other than 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?
- “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.” ⁴ However, travel paid or reimbursed by a non-US entity, including academic and healthcare institutions, governments, companies, or nonprofits, of any dollar amount must be disclosed. ⁴

Possible conflicts of interest or commitment due to interactions with foreign governments, instrumentalities, or entities, including foreign government-sponsored talent recruitment programs that occurred during the twelve months preceding this disclosure, MUST also be reported.

Does the Investigator have affiliations, appointments, or employment at a non-US entity, including consulting and/or advising for a non-US entity?
Has the Investigator participated in a foreign talent recruitment (or similar) program or foreign support provided through an intermediary?
Did the Investigator have travel paid or reimbursed by a non-US entity, including from academic and healthcare institutions, governments, companies, or nonprofits, of any dollar amount?
Did the Investigator receive research support from or have a research engagement with a non-US entity for a project not routed through Bradley University?
Did the Investigator receive in-kind resources (e.g., lab, office, equipment, materials, reagents, personnel, etc.) provided by a non-US entity?

“The disclosure of information indicated in Table 1 will be required across all research agencies, in accordance with the role of the participant in the R&D enterprise." ⁶

Table 1. General NSPM-33 Disclosure Requirements

Disclosures Required From	Organizational Affiliations/ Employment	Employment Positions/ Appointments	Foreign government- sponsored talent recruitment programs*	Current and pending support/ Other Support
Principal investigators (PIs) and other senior/key personnel	Yes	Yes	Yes	Yes

* Foreign government-sponsored talent recruitment program – “Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.” ⁵

Definitions

Sponsored Program: “A sponsored project is an activity sponsored, or funded, by an external organization, such as a federal, state, or private organization or agency.” ³ Characteristics of a sponsored project include a specific scope of work or set of aims, financial accountability (i.e., the funds must be separately budgeted and accounted for), a specific performance period, and deliverables. ³
Investigator: “the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of” ⁴ both active or proposed externally-funded projects.
Institutional Responsibilities: “[A]n Investigator's professional responsibilities on behalf of the Institution, and as defined by the Institution in its policy on financial conflicts of interest, which may include, for example, activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.” ⁴
Significant Financial Interest: A financial interest “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.” ⁴
“The term significant financial interest does not include the following types of financial interests:
- [S]alary, 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;
- or 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.” ⁴
Foreign Influence: A foreign entity with the power to direct or influence the management or operation of an individual or organization or lead to unauthorized access to sensitive information. ⁵
Foreign Talent Recruitment Program: A “program, position, or activity that includes compensation in the form of cash, in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimis value, honorific titles, career advancement opportunities, or other types of remuneration or consideration directly provided by a foreign country at any level (national, provincial, or local) or their designee, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country, to an individual, whether directly or indirectly stated in the arrangement, contract, or other documentation at issue.” ¹

The following activities do not need to be reported if the activity is not funded, organized, or managed by an academic institution or a foreign talent recruitment program on the lists developed under paragraphs (8) and (9) of Section 1286(c) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (10 U.S.C. 1001 note; Public Law 115-233): ¹

“Making scholarly presentations and publishing written materials regarding scientific information not otherwise controlled under current law;” ¹
“Participating in international conferences or other international exchanges, research projects or programs that involve open and reciprocal exchange of scientific information, and which are aimed at advancing international scientific understanding and not otherwise controlled under current law;” ¹
“Advising a foreign student enrolled at an institution of higher education or writing a recommendation for such a student, at such student's request; and” ¹
Engaging in the following international activities:
- “Activities that are partly sponsored or otherwise supported by the United States, such as serving as a government appointee to the board of a joint scientific fund…” ¹
- “[P]roviding advice to or otherwise participating in international technical organizations, multilateral scientific organizations, and standards-setting bodies…” ¹
- “[P]articipating in a Fulbright Commission program funded in whole or in part by a host country government or other routine international scientific exchanges and interactions such as providing invited lectures or participating in international peer review panels.” ¹
- “Involvement in national or international academies or professional societies that produce publications in the open scientific literature...” ¹
- “Taking a sabbatical, serving as a visiting scholar, or engaging in continuing education activities such as receiving a doctorate or professional certification at an institution of higher education (e.g., the University of Oxford…)” ¹
- “Receiving awards for research and development...” ¹

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Bradley University Conflict of Interest Policy for Sponsored Programs

Background

Forms and Resources

Bradley Univeristy Policy

Questions and Answers

Table 1. General NSPM-33 Disclosure Requirements

Definitions

References: