UMBC Conflict of Interest Disclosure Procedures

Individual Financial Conflicts of Interest

UMBC personnel, identified as “key personnel” in any proposal submitted or award recorded in Kuali, are covered by UMBC’s Policies on Financial Conflicts of Interest. These persons are “Investigators”, Co-Investigators, “Project Directors“, etc., and have the responsibility for designing, collecting research data or performing other substantive research activities, and/or reporting research.

Key personnel are required to submit an annual disclosure via the Kuali COI module to meet university policy requirements found in the Interim Policy on Conflicts of Interest in PHS Research as well as the Policy on Individual Conflicts of Interest in Research & Product Development (AKA non-PHS research). Using Kuali COI will satisfy the disclosure at proposal stage requirement for NIH and NSF as well as other federal funding agencies.

The Kuali COI disclosure system allows researchers the ability to submit and update their research related COIs annually and disclose any new reportable interests. To submit or update a disclosure, go to

For for information and training on how to submit your disclosures, See Kuali COI

Important notices regarding PHS funded proposals
  • Investigators submitting proposals for PHS funding are required to complete COI training prior to the beginning of any PHS agency sponsored research award. UMBC uses the CITI training program to document training. Click this link to review the registration process.
  • Investigators submitting proposals for PHS funding are also required to disclose non-grant, non-UMBC funded travel form the past 12 months that relates to your “university responsibilities” that may be seen as a real or perceived conflict of interest. A travel disclosure is performed in Kuali COI –

ORPC will provide educational outreach (via the ORPC myUMBC page as well as in-person education sessions) to provide investigators guidance about using the Kuali COI process.

For additional assistance, please contact the ORPC at 410-455-2737 or

Organizational Conflicts of Interest

The ORPC has created a process to document the three generally recognized categories of Organizational Conflict of Interest:  1) unequal access to information; 2) biased ground rules; and, 3) impaired objectivity.

At present, OCI disclosures must be made via a non-PHS conflict of interest financial disclosure document. Kuali plans to incorporate OCI disclosures in future versions. For now, please follow the steps in the OCI identification and mitigation procedures.

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