COI Review & Management Process
The first step in the review and management process is submission and routing of your Interest and Outside Activity Reporting Form (IOARF). The form can be filed at any time online through NUgrant under the Interest and Activity Management (IAM) module. After you submit the form, the IOARF will be routed to your department chair/director and dean for review and acknowledgement. It will then go to the Conflict of Interest Coordinator for review of financial interests and to your appropriate vice chancellor-level reviewer for review of 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 present your conflict to the Conflict of Interest in Research Committee (CIRC) to develop a custom management plan. The review and approval of outside activities that require management beyond disclosure are completed by the Vice-Chancellor level reviewer.
Financial disclosures should be made by sponsored researchers at least annually. New relevant financial interests or remuneration should be disclosed throughout the year and within 30 days of being acquired.
Review of financial disclosures is completed by the department chair, dean-level reviewer, vice-chancellor-level reviewer and Research Compliance Services. These individuals review outside activities and any financial disclosures to determine if there is a real, potential, or perceived COI. If so, RCS works with the researcher and the Conflict of Interest in Research Committee (CIRC) to prepare an appropriate management plan.
Management of the potential, perceived or actual conflict of interest related to research is completed by the CIRC. The purpose of the CIRC is to review research-related conflicts of interest and approve plans to manage the individual conflict of interest in research. The CIRC is a standing committee selected by the Associate Vice Chancellor for Research and Economic Development acting on behalf of the Vice Chancellor for Research and Economic Development. The committee is composed of seven tenured or tenure track faculty members representing the College of Arts and Sciences, College of Engineering, College of Law, Institute of Agriculture and Natural Resources (the Agricultural Research Division and/or the Cooperative Extension Division) and including the Faculty Senate President and Academic Rights and Responsibilities Committee Chair (or their designees). The CIRC is also informed by several ex officio members who provide expertise from colleges, General Counsel, NUTech Ventures, and the Office of Sponsored Programs. The committee meets approximately once per month during the academic year.
COI training is required to be completed at the time of award for sponsored researchers who receive funding from the Public Health Service (which includes NIH, FDA, CDC and more). Training must be completed every four years.
Examples of Conflicts That May Require Management
Serving as a consultant for a company while performing research at UNL on the company’s technology.
For example, say you are consulting for an outside company. As a result of this consulting relationship, the company wishes to extend an award to you in your capacity as a faculty member at UNL. This may require management, particularly if you have received $5,000 or more in consulting fees from the company.
Owning a company/ stock in a company, while performing research at UNL that is sponsored by the company.
For example, owning a company that wishes to provide a subaward/subcontract to your lab at UNL. This situation may require management. Management could include identifying an alternative PI, informing students involved with the project of your ownership interest in the company, your Department Chair’s notification or oversight, and identifying another investigator that can provide un-conflicted oversight.
Please also note that UNL does not allow faculty/researchers to act as the PI on a project for both the company and in their role at UNL.
Performing federally-funded research that could affect the financial interests of a company in which you have a personal financial interest (i.e., stock or other equity ownership).
For example, if you own a company that commercializes a vaccine you developed and you are simultaneously performing a federally funded study to show the merits of said vaccine. This may require management, particularly if you have equity ownership of a non-publicly traded company.
Involving students, post-docs, and/or trainees in work that could directly benefit a company in which you, as their supervisor, have a personal financial interest.
For example, having students/post-docs/trainees work on a project meant to verify the efficacy of an invention being commercialized by your company. This may require management. Management could include informing students/post-docs/trainees involved with the project of your interest in the company and recusing yourself from the master’s/doctoral Committee in some capacity.
Receiving licensing payments for technology while performing research on that technology.
For example, if you developed a technology that you are licensing to an outside company while also working on a privately or federally sponsored project focused on further testing or development of that technology. This may require management.