UMBC Conflict of Interest Disclosure Procedures
Individual Financial Conflicts of Interest
UMBC personnel, identified as “key personnel” in any proposal submitted via Kuali PropDev, 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. Investigators may include academic appointees, staff, students, unpaid researchers, or consultants.
UMBC is using the Kuali COI module to replace the paper documentation of disclosures 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. The ORPC has created a User Guide with explaining how to use Kuali COI. Please click this link to open and download the current User Guide.
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.
Staff from the 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. Attendance is on a first come first served basis. It is necessary to RSVP for your desired training session. Sessions may be cancelled if no participants register in advance.
For additional assistance, please do not hesitate to contact the ORPC at 5-2737 or compliance@umbc.edu.
Organizational Conflicts of Interest
The ORPC has created a process to document the three generally recognized categories of OCI: 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.