The public looks to university research as an independent, unbiased source of information. Because some university researchers also conduct research for private entities or have private interests in entities that contribute to research, the federal government, State of Nebraska, and UNL require disclosure of these interests.
UNL requires you to disclose interests that have any potential to affect research.
Who must disclose?
Disclosure is required of all university employees, including part-time and full-time employees, visiting faculty/employees, post-doctoral researchers, and graduate students who are involved in research.
Why must I disclose?
Federal regulations require institutions that receive federal funding to establish policies and guidelines for the management of potential conflicts of interest. UNL, in response to these requirements, established a Conflict of Interest in Research (COI) policy. The purpose of the policies and procedures is to protect the credibility and integrity of UNL research to foster public trust and confidence.
When should I disclose?
If you have interactions with, or propose interactions with federal, state, not-for-profit and for-profit entities, whether they involve sponsored funding or not, you are required to complete a Disclosure of Interest (DOI) form annually. The DOI form covers one year of activity. The point of entry to the DOI system is NUgrant, UNL’s electronic research administration system.
How do I disclose?
File all disclosures of interest through NUgrant, UNL's electronic research administration system.
What do I disclose?
You must disclose all significant financial interests from sources that reasonably might have any potential to be related to your research. Some examples of significant financial interests you should disclose to the University include, but are not limited to:
Salary, royalties, or other payments you receive outside the University of Nebraska system that exceed $2,000.00, except for income you receive from public or nonprofit entities for seminars, lectures, or teaching engagements or service on advisory committees or review panels
Equity interests (e.g., stocks, stock options, or other ownership interests) that, when combined for you and your immediate family (including your spouse, parent, parent’s spouse, child or anyone you may claim as a dependent under the IRS Code), exceed $2,000.00 in value if publicly traded or represent more than five percent ownership in a single entity where privately held or the value cannot be determined.
Intellectual property rights (e.g., patents, copyrights, licenses, and royalties from such rights)
Any position you or any member of your immediate family may hold as an officer in a company that seeks to sponsor research with which you will be involved at the University (e.g., Officer, Owner, Partner, Employee, Board Member, Consultant).
If financial interests or circumstances change within the year, for example, the investigator submits an application for industry funding or purchases significant stock in an entity that currently funds their research, a new DOI form should be completed to update this information. The point of entry to the DOI system is available through NUgrant, UNL's electronic research administration system.
If you obtain new reportable financial interests during the annual reporting period that you did not previously disclose, you must complete an updated DOI form within 30 days of obtaining the financial interests.
No. Disclosure is not limited to federally funded projects. You must disclose significant financial interests that could impact the conduct of research regardless of the funding source.
Yes, UNL enthusiastically supports collaborations with small business entities. However, there must be clear distinctions between activities you perform at UNL and activities you perform at the small business site. Typically, all work you do using the campus facilities should focus on longer-range, exploratory research work without immediate commercial value, whereas the work you do at a small business site is more commercially oriented.
Furthermore, you can't be the Principal Investigator for both the work done at the small business entity and the work to be conducted at UNL. If you own a small business entity, you typically may not bring research into your own laboratory under a SBIR/ STTR subcontract from that same small business, without additional review, oversight, and approval by the department, college, and Vice Chancellor for Research, and in concert with a management plan developed by the Conflict of Interest in Research Committee.
Investigator conflicts of interest in research are situations in which financial or other personal considerations may compromise or appear to compromise an investigator's professional judgment in conducting or reporting research. These conflicts typically occur when you have financial interests or business relationships with entities that sponsor your research, license your intellectual property, or may otherwise benefit financially from the results of your research. You may also have financial or business interests with an entity that is not sponsoring your study, but might, for example, have a competing product.
Conflicts of interest, when properly disclosed and managed, will not prevent you from conducting a research project. Delays in the ability to conduct research may occur, however, if you don’t complete the DOI form in a timely manner or if you omit relevant interests from the DOI form. Potential conflicts of interest that are not properly disclosed or managed can prevent you from initiating the research or parts of the research.
In some circumstances, disclosure through completing the DOI form is not sufficient to manage potential conflicts of interest; in these cases, the Conflict of Interest in Research Committee must review the DOI and develop a management plan.
To avoid delays, complete disclosures using the DOI form prior to proposal submission via NUgrant. Then, if further review by the Conflict of Interest in Research Committee is required, a management plan can be developed and in place ready for implementation when the research is awarded to UNL. Minimize any potential delays by disclosing any conflicts using the DOI form as soon as you know about them.
The director of Research Compliance Services reviews the DOI forms to determine whether disclosure of the interest alone is sufficient for managing any potential conflicts. However, if your financial interests constitute substantial conflicts that must be managed, reduced or eliminated before you can conduct research, the Conflict of Interest in Research Committee determines an appropriate strategy for managing any significant potential conflicts.
In order to meet federal, state, and university guidelines, the management plan might include different project or private entity staffing, altered student academic supervision or work arrangements, or in very rare cases, changes in financial interests.
Research Compliance Services, located on the 2nd floor of the Alexander building, can answer your questions about the DOI disclosure process and conflicts of interest. Please contact Dr. Daniel Vasgird, dvasgird2@unl.edu or 402.472.1837.
University employees consulting outside the university should consult the guidance document entitled Guide to Consulting at UNL for additional information.
What do I disclose?
