What is required?
The UM Objectivity in Research Policy requires that Investigators disclose any significant financial interest that 1) For non-Public Health Service grants or contracts: may present a conflict of interest in relationship to externally sponsored projects or 2) For PHS grants and contracts (and some private sponsors): are related to institutional responsibilities (i.e., teaching, research, administrative, or clinical duties). Such disclosures must be made prior to the submission of a proposal for funding. It likewise requires that conflicts of interest be satisfactorily managed, reduced, or eliminated prior to the expenditure of the award or within 60 days of their identification for conflicts disclosed subsequent to an award. If a newly reportable significant conflict of interest arises at any time during the period after the submission of the proposal through the award period, the filing of a disclosure is also required, at that time or at least annually.
Who is covered?
Investigator is defined in the policy as faculty, staff or students serving as Project Directors, Principal Investigators, and members of the research team identified as senior/key personnel on a grant or contract application, progress report, or any other report who are responsible for and have substantial independent decision making in respect to the design, conduct or reporting of the research, such as Collaborators or Consultants named on an externally sponsored grant. External sponsor means any granting agency outside the University, including both governmental and non-governmental sponsors.
What must be disclosed?
This varies for PHS and non-PHS grants or contracts due to different federal regulations. PHS Investigators must complete BOTH forms below. For details:
See the General form here.
See the PHS form here.
PHS form should be filled out if the sponsor is one of the following:
US Public Health Service Agencies (including NIH, CDC, HRSA and FDA)
American Heart Association
American Cancer Society
Susan G. Komen Foundation
Alliance for Lupus Research
Juvenile Diabetes Research Foundation
Lupus Foundation of America
Public Health Services Significant Financial Interests
PHS SFIs That Must be Disclosed
- Interests that reasonably appear to be related to teaching, research, administrative, or clinical duties
- Received during the past 12 months
Excluded Financial Interests
- Salary, royalties, or other remuneration paid by UM to you if you are currently employed or otherwise appointed by UM
- Intellectual property rights assigned to UM and agreements to share in royalties related to such rights
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made in these vehicles
- Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency, an Institution of higher education as defined in 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
- Income from service on advisory committees or review panels for a U.S. 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
Interests held individually by the Investigator, his/her spouse, and dependent children must be added together and the aggregate value used to determine limits listed below
I. With regard to any publicly traded entity:
The value of any remuneration and the value of any equity interest in the entity, when aggregated, exceed $5,000.
(Remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship)
(Equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value)
II. With regard to any non-publicly traded entity:
The value of any remuneration received from the entity, when aggregated, exceeds $5,000
When you (or your spouse or dependent children) hold any equity interest (e.g., stock, stock option, or other ownership interest)
III. Any intellectual property rights and interests (e.g., patents, copyrights not assigned to UM), upon receipt of income related to such rights and interests.)
IV. Any reimbursed or sponsored travel (i.e., travel paid for on your behelf but not reimbursed by UM & related to your UM research, administrative, clinical, or teaching duties)
Excluded is travel that is reimbursed or sponsored by the following:
- A US Federal, state, or local government agency
- A US Institution of higher education, academic teaching hospital, medical center
- A research institute affiliated with a US Institution of a higher education
- Investigators must disclose their Significant Financial Interests utilizing the Significant Financial Interest Disclosure Form and attaching supporting documentation. The completed form(s) and documentation must be submitted to the Office of Research and Sponsored Programs Director of Integrity and Compliance with the proposal and the Transmittal Sheet for Sponsored Projects. Supporting documentation should be sealed in an envelope marked confidential and must accompany the Disclosure Form.
- Resolutions to conflicts of interest will be incorporated in a Memorandum of Understanding (MOU) that is executed between the Investigator(s), the Investigator’s cognizant University official (usually a dean or director), and the Vice Chancellor for Research and Sponsored Programs prior to expenditure of award or within 60 days of their identification for conflicts disclosed subsequent to an award.
See Procedures Flow Charts for more information.
Two Common Situations that Require Conflict of Interest Management Plans
- The faculty member assigns students, postdoctoral fellows, or other trainees or employees to projects of interest to or supported by a business (through sponsored research or a contribution) in which they, an immediate family member, or an associated entity has a financial or business interest (other than royalty income).
- The faculty member or his or her department receives University-supervised sponsored research support or contributions (in dollars or in kind) from a business in which they, an immediate family member, or an associated entity has a financial or business interest.