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2025 New Conflict of Interest Policy

New Conflict of Interest and Conflict of Commitment Policy

Oct. 1, 2025


Dear Colleagues,

As a follow-up to the message you received on September 5, 2025 from Provost McIntyre and Vice President Gage regarding the new BOT 414: Conflict of Interest and Conflict of Commitment (COI/COC) Identification and Disclosure Policy, I am writing to share next steps, highlight changes in policy, and provide resources to support you in this transition. The new policy takes effect today, October 1.

Background

On June 13, 2025, the Board of Trustees approved a new Conflict of Interest and Conflict of Commitment (COI/COC) Identification and Disclosure Policy (BOT 414). This new policy replaces two long-standing policies — Outside Work for Pay (BOT 409) and Conflicts of Interest, Faculty/Academic Staff (BOT 503) — and establishes one comprehensive framework for disclosure and review of outside activities.

MSU values the professional, scholarly, and entrepreneurial activities that faculty pursue beyond the university. This policy is designed not to limit those contributions, but to support them responsibly — ensuring transparency and safeguarding both individual faculty and the university community.

Why This Policy and Why Now

The shift to a unified policy was driven by regulatory requirements. National guidance such as the National Security Presidential Memorandum-33 (NSPM-33) and the CHIPS and Science Act of 2022 require stronger, standardized disclosure practices at universities receiving federal funding. One of the key requirements is the requirement that institutions adopt clear, comprehensive policies addressing both COI and COC. This includes disclosing:

  • Financial and non-financial external relationships,
  • Paid and unpaid professional activities,
  • International affiliations, talent recruitment programs, and
  • Situations where time or effort may be diverted from institutional responsibilities.

The new framework helps protect faculty and the institution by clearly defining what must be disclosed.

Key Policy Changes You Should Know

The new policy introduces several important updates. Provided below are some of the key changes:

  • Unified policy framework: Combines COI and COC into one policy covering paid, ranked faculty, academic administrators, executive managers, and investigators.
  • Clear definitions: New and updated key terms, including Outside Activities, Institutional Responsibilities, Scholarly Activity, Conflict of Commitment, and Significant Financial Interest.
  • Broader scope: Applies to both paid and unpaid outside activities related to disciplinary expertise.
  • Outside Activities Time Limit: Individuals on full-time appointments may spend up to an average of four days per month (during their duty period) on approved outside activities (paid and unpaid).
  • Academic year faculty: Outside activities during the non-duty summer period (May 16–August 15) now require approval. But the time limit does not apply.
  • Electronic forms: Launch of two new electronic tools (more information below).

New Electronic Forms
To support implementation, we are launching two updated electronic tools:

The Conflict of Commitment form replaces the former paper-based Outside Work for Pay process and introduces a more streamlined way to disclose and manage outside activities. Please keep in mind:

  • The new forms are in an early release (or beta) phase and are currently intended for submitting new activities.
  • Over the next few months, we will continue to enhance the system with new features, including integrations and usability improvements.
  • Our goal is to make the process as simple and efficient as possible to support COI/COC compliance.
  • These forms should be used if you are starting a new activity related to your institutional responsibilities. If you are required to complete a conflict of interest disclosure, please update it with new activities and interests, annually or within 30 days of a change.
  • As a reminder, if you participate in federally funded research, you must follow federal disclosure requirements and report your research activities. MSU requires all disclosures to external sponsors to be current, accurate, and complete. For guidance on what to disclose to federal sponsors, visit the Research Security Disclosures and Training website or contact the ORI Talent Programs group.

What This Means for You

  • Any new outside activities (paid and unpaid) must be submitted into Kuali Build and approved before engagement.
  • Activities approved under the previous Outside Work for Pay policy do not need to be re-submitted for approval at this time.
  • We recognize that the 2025–26 academic year will be a transitionary period where faculty will adjust to the new policy.
  • Individuals covered under the policy should continue to complete their annual COI disclosure in Kuali Research. The annual disclosure will now ask for disclosure of paid and unpaid activities related to your institutional responsibilities.
  • Faculty on academic year appointments must disclose and seek approval for outside activities (paid and unpaid) during the summer non-duty period. Note: time limits do not apply.

Resources and Support
 To support your transition, the CDM website has several resources available. We highlight a few here:

Additional resources and guidance will be added to the CDM website in the coming weeks. Additionally, we are also collaborating with dedicated policy implementation liaisons from each college in order to foster clear communication, consistency, and support for those covered by this policy. They will be providing feedback on implementation with the Office of Conflict Disclosure and Management (CDM) and the Office for Faculty and Academic Staff Affairs (FASA) on implementation of the policy within their college.

Questions may be directed to the Office of Conflict Disclosure and Management at cdm@msu.edu or Faculty & Academic Staff Affairs at fasaffairs@msu.edu.

Thank you for your continued support as we move forward with this important initiative.

Laura R McCabe, Ph.D.
Associate Vice President
Office of Research & Innovation
Research Regulatory Support

Teresa Mastin, Ph.D.
Vice Provost and Associate Vice President for Faculty and Academic Staff Affairs
Office of the Provost