This video is provided by Ethics Unwrapped and is a free educational resource from The University of Texas at Austin.
What is a conflict of interest?
- A conflict of interest is any situation or relationship (personal, professional, commercial or financial) that may compromise or appear to compromise a covered individual's professional judgment in carrying out their institutional activities because of an external relationship/interest of the employee or the immediate family members.
What is a financial disclosure form and where is it located?
- A financial disclosure form is the mechanism in which investigators at Mississippi State University disclose their Significant Financial Interests so the University can determine if a financial conflict of interest exists.
- Beginning January 5, 2026, disclosure forms are to be submitted through your Cayuse account. For instructions on how to submit a disclosure form through Cayuse, click HERE.
Who must submit a financial disclosure form?
- A financial disclosure form is required by any investigator who:
- Is listed as key personnel on a proposal or an award for external funding;
- Is involved in the design, conduct, or reporting of a federally funded research program; and
- Has a Significant Financial Interest in an entity that overlaps with their external funding, regardless of if it is federal or not.
What must be disclosed on the financial disclosure form?
- Any Significant Financial Interest that you or your immediate family has;
- Information regarding the participation in a Foreign Government Talent Recruitment Program; and
- Other Support.
What is a Significant Financial Interest?
- A "Significant Financial Interest" (SFI) means a financial interest consisting of one or more of the following that is related to your Institutional Responsibility (professional expertise):
- $5,000 or more in salary, consulting fees, advisory board fees, remuneration, honoraria, gifts, or "in kind" compensation from an outside entity in the past 12 months.
- $5,000 or more in equity or ownership interest (including stock options) in a publicly-traded company.
- Any equity or ownership interest in a private company (e.g., start-up company).
- An appointment to serve in a fiduciary role (director, officer, partner, trustee, or any position of management) for an outside company whether or not remuneration is received.
- Receipt of patent/copyright licensing fees or royalties from an outside entity.
- Any travel that is sponsored or reimbursed by an outside entity.
- Any compensation whose value could be affected by the outcome of research conducted at MSU.
What is a Foreign Government Talent Recruitment Program?
- A "Foreign Government Talent Recruitment Program" (FGTRP) is a program sponsored by some foreign governments or affiliates with distinguishing features that generally include compensation and recruitment. To learn more about FGTRPs and foreign influence management, click HERE.
What is Other Support?
- "Other Support" includes all outside resources (from foreign and domestic entities) directly supporting your research endeavors, regardless of whether or not they have monetary value. This includes (but is not limited to):
- Titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary).
- Research resources such as personnel, lab space, scientific materials, or high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.).
Are there financial interests that I do not have to disclose?
- Yes, you do not need to disclose the following:
- Salary or other remuneration received from Mississippi State University, including salary received from external sources through sponsored agreements administered by the University;
- Intellectual property rights assigned to Mississippi State University and agreements to share in royalties related to such rights;
- Standard royalties received for published scholarly work or other professional writings;
- 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; or
- 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.
If I have outside employment, is that a Significant Financial Interest?
- If your outside employment is related to your institutional responsibilities (what you do on behalf of MSU) and you received more than $5,000 in the 12 months prior to your disclosure date, then it is a Significant Financial Interest and should be listed on your Financial Disclosure Form.
- Remember that you must also get approval for Outside Employment through the Outside Employment Request Form in eForms. Submitting a Financial Disclosure Form does not grant approval for outside employment activities nor does submitting an Outside Employment Approval Request Form satisfy the FCOI disclosure requirements!
Who determines if I have a conflict of interest?
- Each time you route a proposal or an award for review, you are required to complete a Research Based Disclosure. This form is reviewed by ORC&S to determine if there is overlap with the project.
Can I still conduct the research if I have a conflict of interest?
- If it is determined that a conflict exists, a Management Plan will be created to ensure that a researcher's personal interest in the outside entity does not compromise or appear to compromise his/her objectivity in performing the research project, mentoring students involved in the research project, or reporting the results of the project.
What is a Management Plan?
- If it is determined that a conflict of interest exists, a Management Plan will be created to manage the conflict. All approved Management Plans are developed, reviewed, approved, and annually monitored by the university's COI Administrator, working as needed with the Conflict of Interest Review Committee. Management Plans are reviewed annually for renewal and are effective as long as the conflict is present. If a Significant Financial Interest relating to your Institutional Responsibilities is determined to constitute a Financial Conflict of Interest with respect to the research activity, the appropriate report describing the Management Plan shall be submitted to the funding agency by MSU.
- This management plan will then be sent to your immediate supervisor for signature.
What is the difference between an Annual Disclosure and an RBD?
- An Annual Disclosure is a blanket disclosure form that is not tied to any specific project. It requires the investigator to report all SFIs related to their institutional responsibilities. Annual Disclosures must be updated each year and within 30 days of acquiring a new SFI.
- An RBD is tied to a specific project. It must be completed by all key personnel listed on the project. RBDs are required at the proposal routing stage and again at the award routing stage. The Annual Disclosure and the RBD collect nearly the same information, but the RBD includes one additional question (how the SFIs you’ve disclosed are related to that particular project).
Who is required to complete an Annual Disclosure and when should this form be completed?
- An Annual Disclosure form is required for 1) any investigator who is involved in the design, conduct, or reporting of a federally funded research program, or 2) anyone who has an SFI in an entity that overlaps with their external funding, regardless of if it is federal or not. Annual Disclosures must be renewed each year while the investigator continues to meet either of the requirements above. Once an Annual Disclosure is on file, the investigator must update it annually and within thirty (30) days of acquiring a new SFI.
Who is required to complete an RBD and when should this form be completed?
- An RBD form is required for anyone listed as key personnel on a proposal or an award. This form is tied to a specific project and is completed by all key personnel listed as key personnel on the project at the proposal review stage and the award review stage.
How do I access and complete an Annual Disclosure?
- Investigators complete their Annual Disclosure in Cayuse. Instructions on how to access and complete this form can be found HERE.
How do I access and complete an RBD?
- Investigators complete RBDs in Cayuse. Instructions on how to access and complete this form can be found HERE.
Do the Annual Disclosure and RBD forms save my prior disclosure information?
- Yes. Once you submit a disclosure, Cayuse retains your information and will auto populate it in future disclosures. You can review the information and make any necessary updates before submitting.
Can I complete an RBD before having an Annual Disclosure on file?
- Yes. During the University’s transition to the Cayuse system, there may be many instances where an investigator’s first disclosure in Cayuse will be a RBD.
What happens after I submit my disclosure?
- After you submit your disclosure, it will enter a queue for ORC&S to review and approve. Our office monitors this queue regularly throughout the day. Because Cayuse updates overnight, the approval status may not be visible to you or staff in the Office of Sponsored Programs until the following day.
Where can I view the status of my disclosure form?
- Investigators can view all of their disclosures and check the status of each on their COI Disclosure page in Cayuse. The status of a disclosure will be listed as “Unsubmitted,” “Under Review,” or “Disclosure Complete.” To access your COI Disclosure page:
- Log in to Cayuse at https://msstate.app.cayuse.com/
- Click on your name in the upper right corner, then select “My Profile”
- Once on your My Profile page, select “COI Disclosures” under the tab on the lefthand side
- Once on your COI Disclosures page, you will be able to view all disclosures that you have completed through the Cayuse system
What does the resolution status of my disclosure mean?
- After your disclosure is reviewed by ORC&S, it will be assigned a resolution status. Each disclosure falls into one of the following three categories:
- COI determined and managed - means that you reported a Significant Financial Interest (SFI) on your disclosure form. After review, ORC&S determined that a potential or real conflict exists but can be appropriately managed through an approved management plan.
- COI determined and unmanageable - means that you reported an SFI on your disclosure form. After review, ORC&S determined that the potential conflict cannot be managed at this time. Additional review, restrictions, or institutional action may be required before the related research activity can proceed.
- No COI determined - means that you either reported no SFIs on your disclosure form, or that any of the SFIs disclosed were reviewed and determined not to constitute a conflict of interest based on the information available at the time of review.
If I have an active FCOI Disclosure eForm on file, do I need to complete an Annual Disclosure in Cayuse?
- No. ORC&S will not require you to complete an Annual Disclosure in Cayuse until your FCOI eForm expires. Approximately one month before the expiration date, ORC&S will send you a reminder email notifying you that your form is nearing expiration. That email will prompt you to complete the Annual Disclosure in Cayuse and will contain instructions on how to do so. One exception applies. If you are listed as key personnel on a proposal or award that is being routed for review, you will be required to complete an RBD in Cayuse for that specific project.
How do I view my old FCOI Disclosure eForms?
- To view your previously submitted disclosure forms in eForms:
- Log in to your myState account at https://my.msstate.edu/
- Under the Apps & Services menu on the lefthand side, select “eForms”
- In the upper lefthand corner, click the “eForms Search” button
- In the search fields, set the date range you need and choose the Document Types as Financial Conflict of Interest (FCOI) Disclosure Form, then click “Search”
- Your submitted disclosure forms (for the dates you selected) will appear in the results
Who is required to complete COI training?
- All investigators working on federally-funded research or submitting a proposal for such funding are required to complete COI training at least every four years.
How do I take the COI training?
- COI training is a CITI course consisting of 2 modules. Instructions for accessing the training can be found HERE.
How can I find out if my COI training has expired?
- You can find a list of all your research compliance related training and their expirations HERE.