9.2 Financial Conflict of Interest Disclosure for Federal Awards Policy

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Chapter 9: Grants and Sponsored Projects

9.2 Financial Conflict of Interest Disclosure for Federal Awards Policy

Related Minnesota State policy:

Related Minnesota State procedure:

Board Policy 1C.2, Fraudulent or Other Dishonest Acts (http://minnstate.edu/board/policy/1c02.html)

1C.0.1 Employee Code of Conduct, Part 3, Subpart A. Conflict of Interest (http://minnstate.edu/board/procedure/1c0p1.html)

Related Policy from Grantee Standards: Conflict of Interest Policies in the NSF Proposal and Award Policies and Procedures Guide, Part II - Award & Administration Guide. Related Policy from the Code of Federal Relations:  https://www.nsf.gov/pubs/policydocs/pappg19_1/nsf19_1.pdf
Related Policy from the Code of Federal Relations: 42 CFR 50 Subpart F (https://www.ecfr.gov/cgi-bin/text-idx?rgn=div5&node=42:
45 CFR 94 (https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title45/45cfr94_main_02.tpl)


To protect the design, conduct, and reporting of externally-funded projects from potential bias by defining financial conflicts of interest as they relate to conducting activities supported by Federal awards; and to provide a process for faculty and staff to complete appropriate disclosure to comply with Federal regulations.

Policy Scope:

In addition to policies and procedures approved by the Minnesota State Board of Trustees and those provided by the State of Minnesota, this Financial Conflict of Interest Disclosure for Federal Awards policy applies to any Federal award and any transactions covered by Federal grant funds. This policy is applicable to all Normandale employees.

Part 1: Definitions

Family means any member of the Investigator’s immediate family, specifically, any dependent children and spouse, domestic partner identified for purposes of employee benefits, or an organization which employs or is about to employ any such person.

Financial Interest means anything of monetary value received or held by an Investigator or an Investigator’s family, whether the value is readily ascertainable, including but not limited to:

  • Salary or other payments for services (e.g. consulting fees, honoraria, or paid authorships for other than scholarly works)
  • Any equity interests (e.g. stocks, stock options, or other ownership interests)
  • Intellectual property rights and interests (e.g. patents, trademarks, copyrights) upon receipt of royalties or other income related to such intellectual property rights and interests.

For Investigators, financial interest also includes any reimbursed or sponsored travel undertaken by the Investigator and related to their institutional responsibilities that is not reimbursed or sponsored by the grantor, a Federal, state, or local government agency, or 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. This includes travel that is paid on behalf of the Investigator as well as travel that is reimbursed, even if the exact monetary value is not readily available.

Financial Interest does not include:

  • salary, royalties, or other remuneration from Normandale;
  • income from the authorship of academic or scholarly works;
  • income from seminars, lectures, teaching engagements or services sponsored by or from advisory committees or review panels for U.S. Federal, state or local governmental agencies, U.S. institutions of higher education, research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers;
  • equity interests or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions made in these vehicles; or
  • any ownership interests in the organization if the organization is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program.

Financial Conflict of Interest means a significant financial interest that Normandale reasonably determines could directly and significantly affect the design, conduct, or reporting of federal grant-sponsored research, projects, or programs.

Institutional Official is the individual within Normandale who is responsible for the solicitation and review of disclosures of Significant Financial Interests including those of the Investigator’s Family related to the Investigator’s Institutional Responsibilities. For purposes of this policy, the Institutional Official is the Director of Grants and Sponsored Projects or other such employee as the Director of Grants and Sponsored Projects may designate in writing.

Institutional Responsibilities means the Investigator’s professional responsibilities associated with their appointment or position at Normandale, such as teaching, administration, and institutional, internal, and external professional committee service.

Investigators are any principal investigator (PI), co-principal investigator (co-PI), project director (PD), or other key personnel working on a project or program funded by any federal agency. Sub-grantees must also fill out a disclosure form or provide certification from their organization that they comply with federal policies regarding disclosure of financial conflicts of interest.

Significant financial interest means a Financial Interest that reasonably appears to be related to the Investigator’s Institutional Responsibilities, and:

  • If with a publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure, and the value of any equity interest during the 12 month period preceding or as of the date of disclosure, exceeds $5,000; or
  • If with a non-publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure exceeds $5,000; or
  • If with a non-publicly-traded company, is an equity interest of any value during the 12 month period preceding or as of the date of disclosure; or
  • Is income exceeding $5,000 related to intellectual property rights and interests not reimbursed through Normandale, or
  • Is reimbursed or sponsored travel related to his or her Institutional Responsibilities.
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Part 2: General Provisions
Part 2: General Provisions
  • No employee or agent of Normandale may participate in the selection, award, or administration of a procurement or non-procurement contract supported by a Federal grant if he or she has a real or apparent conflict of interest.
  • A real or apparent conflict of interest exists when the employee or agent, or any member of their Family has a financial or other interest in, or would receive a tangible personal benefit from, the vendor being considered for the contract.
  • Normandale’s employees and agents are prohibited from soliciting or accepting gratuities, favors or anything of monetary value from contractors or parties to subcontracts unless such unsolicited gratuity or favor is considered by Minnesota State procedure 1C.0.1, part 3, subpart B to be nominal in value.
  • Circumstances that arise that potentially or actually involve conflicts of interest must be promptly and fully disclosed to the Institutional Official by the employee, officer or agent by completing the Financial Interests Report.
  • The Financial Interests Report must also be completed prior to the submission of proposals to Federal agencies, annually thereafter if Normandale is awarded financial assistance from the Federal agency, within 30 days of a person’s appointment or employment as an Investigator, or within 30 days of an Investigator discovering or acquiring a Significant Financial Interest.
  • Disciplinary actions for violations of this Policy will be determined by Normandale in accordance with existing policies, procedures and/or contracts applicable to the officer or agent.
  • The Institutional Official will notify the Federal awarding agency in writing of any potential or actual conflict of interest by an employee or agent pursuant to the awarding agency’s policy.
  • Normandale will require sub-recipients to maintain a conflict of interest policy for Federal awards or follow this Policy as if it were directly applicable to the subrecipient.

Part 3: Responsibilities


Subpart A: Office of Grants and Sponsored Projects. The Institutional Official is responsible for:

  • Distributing the Financial Conflict of Interest Disclosure Form to all investigators and sub-grantees, providing training, and ensuring that the forms are completed as identified in Subpart B, Responsibilities for investigators; 
  • Reviewing all disclosures to determine if a potential conflict of interest exists;
  • Maintaining negative disclosures (those that show no conflict of interest) on file in accordance with federal and state requirements;
  • Forwarding positive disclosures (those which indicate a potential conflict) to the Conflict of Interest Review Committee;
  • Reporting the existence of a potential conflict of interest to the federal funding agency prior to the expenditure of any funds. 

Subpart B: Investigators. Investigators (PIs, co-PIs, project directors, and others in key roles) must complete a Financial Conflict of Interest Disclosure Form and submit it to the Office of Grants and Sponsored Projects:
• Prior to submission of any federal funding application;
• Annually by October 1st of each year of a grant-funded program;
• Within 30 days of discovering or acquiring a new significant financial interest.

Any investigator who knows of, or could reasonably be expected to know of, this policy and deliberately fails to disclose or respond to a potential conflict of interest shall be subject to disciplinary action in accordance with the applicable bargaining unit, ranging from reprimand to discharge.

Subpart C: Conflict of Interest Review Committee. Positive disclosures (those which indicate a potential conflict) will be reviewed by a committee composed of the director of grants & sponsored projects, vice president of finance and operations, vice president of the area submitting the grant, and vice president of human resources. The committee will determine how the conflict will be managed, reduced, or eliminated and communicate its action plan to key personnel. 

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Policy History
Date of Adoption: 11/2/2017
Department Owner: Grants
Date and Subject of Revisions:
4/2/19 Updated Related Policy and Procedure Links, added Policy Scope, Definitions added and clarified, General Provisions added.
Next Review Date: 4/2/2023

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