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UMBC Procedures for Reporting Individual Financial Conflicts of Interest in Non-PHS Research

Investigators, who have the responsibility for the design, conduct or reporting of non-PHS funded research (examples of agencies), are required to disclose any situation that could conceivably be viewed as a conflict of interest or a reportable financial interest using the procedures found in UMBC’s Policy on Individual Conflicts of Interest in Research & Product Development. Such disclosures should be made at the earliest possible time to afford the best protection of an investigator’s interests. When in doubt, it is safer to disclose.

Disclosure Process

At the time a proposal is submitted, any individual who is considered an “Investigator” in proposed submissions is required to complete and sign a COI Financial Disclosure Form for each proposal. This form must be submitted to the Office of Research Protections and Compliance at the time a proposal is submitted to the Office of Sponsored Programs.

Note: there is no requirement for disclosing travel or mandatory conflict of interest training for non-PHS funded COI disclosures.

If your role in a non-PHS proposal involves acticities such as budget preparation, planning activities, studies and analyses to support agency policies, development of regulations, evaluation services, alternative dispute resolution, FOIA response preparation, agency training, access to confidential or sensitive information, or providing legal advice that is “closely associated with inherently governmental functions” (as described in FAR 79 FR 18503 – Section 3.11), a disclosure is required as well. Contact the ORPC for more information about this requirement.

Review Process

Upon submission, the ORPC will screen the disclosure information in the COI Financial Disclosure Form  for applicability and completeness. As necessary, the form is then submitted to the Assistant Vice President for Research (AVPR) for review to determine if any action is required and if necessary, create a COI Management Plan to manage, reduce or eliminate the Conflict of Interest. This review may also require a meeting of a Conflict of Interest Committee to decide certain activities may be prohibited when potential Conflicts of Interest are too difficult to manage, reduce, or eliminate.

Once the AVPR has developed an appropriate COI Management Plan, a copy will be provided to the individual and his/her department chair or supervisor for review and comment. Once finalized, COI Management Plans are submitted to University Counsel for review and to the UMBC President for the final decision to accept or reject a COI Management Plan.

Continuing obligations concerning conflict of interest

Investigators are responsible for updating disclosure forms annually during the period of the research, and within 30 days of identifying, changing or acquiring a new financial interest. ORPC will send notification prior to the anniversary of the initial COI disclosure to update any information.

Forms

COI Financial Disclosure Form – 06/13/2014

last updated: 06/23/2014