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 financial interests.
UNL requires disclosure of interests that appear to be related to your institutional responsibilities.
Federal regulations require institutions that receive federal funding to establish policies and guidelines for the management of potential conflicts of interest. The purpose of these policies and procedures is to protect the credibility and integrity of UNL and to foster public trust and confidence.
The disclosure process is not intended to discourage participation in activities outside of UNL.
Financial interests that reasonably appear to be related to your institutional responsibilities must be disclosed on an annual basis by filing an Interest and Outside Activity Reporting Form (IOARF) on NUgrant. Financial interests include, but are not limited to:
Consulting income, royalties, salary or other payments you receive outside the University of Nebraska system
Equity interests (e.g., stocks, stock options, bonds or other ownership interests) in entities related to your institutional responsibilities
Intellectual property rights and interests (e.g., patents, copyrights, licenses) upon receipt of income to such rights and interests
If you are receiving funds from a Public Health Service awarding agency, sponsored or reimbursed travel must be disclosed
Such financial interests include interests related to a covered person's immediate family, business relationships, fiduciary relationships, or investments.
The following interests do not need to be disclosed:
Interests that do not reasonably appear to be related to your institutional responsibilities
Salary, royalties, or other remuneration paid by UNL
Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, a U.S. institution of higher education, an academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education.
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.
"Institutional responsibilities" are activities such as procurement, research, teaching, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
Immediate family is defined as your spouse, child, parent, brother, sister, grandchild, or grandparent, by blood, marriage, or adoption, or an individual who is your Adult Designee. Therefore, interests held by the parents of your spouse would be considered financial interests that would need to be disclosed if they are related to your institutional responsibilities.
Funding that is routed through the appropriate University channels (such as the Office of Sponsored Programs) would not need to be reported. All payments you receive directly from an outside entity must be disclosed if they appear to be related to your institutional responsibilities.
Your IOARF will be routed to your department chair/director and director. It will then go to Research Compliance Services for review of financial interests and to your appropriate vice chancellor for review of your outside activities. Often, disclosure of financial interests is sufficient. In situations where potential conflicts of interest must be managed beyond disclosure, Research Compliance Services will work with you to either:
Choose a standard method for managing the conflict as listed in the UNL Conflict of Interest in Research Policy; or
Present your conflict to the Conflict of Interest in Research Committee to develop a custom management plan.
Your IOARF is valid for one year from the approval date. If your financial interests or circumstances change during the annual reporting period, a new IOARF should be completed to update your disclosure within 30 days of a change in your outside interests. The information from your previous form will be pre-populated so that you may quickly and easily make changes.
Conflicts of interest, when properly disclosed and managed, will not prevent you from conducting research. Delays in the ability to conduct research may occur, however, if you do not complete the IOARF in a timely manner or if you omit relevant interests from the form.
Maintaining an accurate and up-to-date IOARF is crucial in ensuring that UNL complies with state and federal reporting regulations. Failure to update your IOARF may result in loss of sponsored research funds and may require the University to conduct a retrospective review of the research to ensure no bias has been introduced into research activities.
Expanded definition of investigator
– PHS now defines an investigator as 'the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.'
Timeframe for disclosure
- To comply with the new regulation, all investigators must complete the IOARF by the time of submitting proposals for all PHS-funded research. It is the principal investigator's responsibility to identify all investigators on the grant prior to submission and submit that list to their grant coordinator. Should an award be made, it is the principal investigator's responsibility to ensure that the list is kept current during the life of the grant. Any changes must be sent to their post award coordinator.
Required conflict of interest training
– All PHS investigators must complete mandatory training on conflict of interest at least every 4 years. The IOARF will prompt investigators to take the NIH training at http://grants.nih.gov/grants/policy/coi/tutorial2011/fcoi.htm. They will then attach their completion certificate to the IOARF. Internet Explorer 9 should be used to ensure the ability to save an electronic copy of the completion certificate.
Disclosure of sponsored/reimbursed travel
– PHS now requires that some sponsored or reimbursed travel be disclosed on the IOARF no later than 30 days after the travel has occurred. Some exceptions apply. Investigators do not need to disclose:
Travel sponsored by:
A federal, state, or local government agency
US institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a US institution of higher learning
Travel that is included in a grant/project proposal that is administered by UNL's Office of Sponsored Programs
Public accessibility requirement – Identified financial conflicts of interest held by senior/key personnel must be made publicly available within 5 business days of receiving a written request for such information.