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Financial Conflict of Interest in Sponsored Programs - Compliance with Federal & State Law

Office of Origin: Grants and Foundations
Date Adopted: 10-22-96
Date Reviewed: 11-22-08
Last Date Modified & Approved: 01-27-09

Policy Statement:
Lake Michigan College shall protect Federal and State-funded programs from any bias that can be expected to arise from the financial interests of Project Directors and employees. In accordance with Federal and State regulations, key personnel involved in projects funded by Federal and State grants must sign the "Conflict of Interest Form." A conflict of interest exists when persons affiliated with a project funded by federal and state sources may have the opportunity to influence the project's business decisions in ways that could lead to personal gain or give improper advantage to themselves, immediate family or any corporation, partnership or unincorporated entity in which he or she possesses an ownership as defined by the College below. Such conflicts could affect the design, conduct or reporting of project results.

I. Definitions

• An External Entity includes any person, trust, organization, enterprise, or other entity (including government agencies) that is not an entity under the control of or under common control with the College.

Immediate Family of an individual includes his/her spouse and children.

• A Financial Interest is anything of significant monetary value including but not limited to salary or other payments for service (e.g. commissions, consulting fees, or honoraria), equity interests (e.g. stocks, stock options, or other ownership interests), allowance, forbearance, forgiveness of debt, interest in real or personal property, dividends, royalties derived from the licensing of technology, rent, capital gain, and intellectual property rights (e.g. patents, copyrights, and royalties from such rights).

Whether a financial interest is "significant" will depend upon the facts of the situation, but monetary value will be considered significant according to the following guidelines: (1 ) an equity interest is significant if it exceeds $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value or represents more than a 15% ownership interest in any single entity, when aggregated for the director and his/her immediate family; (2) salary, royalties, or other payments are significant if they are expected to exceed $10,000 when aggregated for the director and his/her family members over the 12 months following the date of the disclosure.

The term does not include:
(1) salary, or other remuneration from Lake Michigan College;
(2) income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities; or
(3) income from service on advisory committees or review panels for public or non-profit entities.

Director or Investigator is any person, including but not limited to, any person holding professional appointment at the College, who is engaged in the design, conduct, or reporting of externally-supported educational activities through federal and state agencies.

Sponsored Program means, training, and instructional projects involving funds, materials, gifts, or other compensation from external entities under agreement with the College.

II. Updating of Financial Disclosure The report form will be updated by October 1 of each year.

Responsibility: Director, Grants and Foundations