Conflict of Interest (COI) FAQs

The University of Nebraska (NU) Executive Memorandum No. 36 requires the following individuals to complete a COI/COC Annual Disclosure form: 

• All full-time faculty, including those with nine-month appointments; 
• Managerial/professional staff and administrators; 
• Anyone who is responsible for the design, conduct, administration, or reporting of research; 
• Anyone with an outside professional activity involving a foreign government, quasi-government, institution, or other foreign entity (including businesses); 
• All employees who have been issued a University purchasing card; 
• All employees with delegated signature authority; and 
• Anyone who is otherwise directed to complete the disclosure form 

Additionally, Adjunct Faculty, International Scholars, and/or Retired/Emeriti Faculty may need to complete an annual COI/COC Disclosure if they have an outside activity that could overlap with any UNL involvement and/or receive funding/support from a foreign government, quasi-government, institution, or other foreign entity (including businesses). 

If your role is not listed as part of the EM 36 covered persons above, you are not required to complete an annual disclosure unless you have an outside activity that could impact your institutional responsibilities/work.  

For example:

Staff members who are not involved in research, are not Managerial/Professional, and do not have signature/purchasing authority do not need to complete disclosure. If an outside activity arises that could overlap or impact your UNL responsibilities, however, you will need to proactively disclose and seek approval prior to beginning the outside activity. 

Similarly, students not involved in research do not need to disclose, unless an activity is being considered that could impact your UNL student involvement/work. 

Login to NuRamp using your True You credentials. On the homepage, click on COI/COC Disclosure and then click [add disclosure] to start a new form.

If you still have a question about completing the form, please reference our Video Resources webpage and/or contact the COI staff (472-6965 or unlcoi@unl.edu).

Yes, if you are in one of the employee categories listed above, you are required to complete an annual disclosure. A COI/COC Disclosure must be completed by each individual meeting the description of a covered person (above), even if they do not have any outside interests or activities to disclose.

If you do not fall under one of the EM 36 categories listed above, you are only required to disclose if you have a potential or actual COI/COC.

NuRamp is programmed to automatically approve disclosures that do not have anything to report. You should receive a very quick/automated approval notification from the system once you submit your disclosure. However, NuRamp will also generate a monthly report that is sent to your direct supervisor/chair with a compiled listing of all those under their supervision that did not have anything to disclose. If your supervisor/chair is aware of any outside activities or other disclosure requirements that have been missed, they will follow up to ensure you complete a change request to document the situation they deem needs disclosed. As a reminder, all employees are responsible for transparently and accurately completing disclosure, as reflected through the attestation at the end of each form submission.  

UNL not only permits but encourages its employees to engage in outside professional activities with industry and other external entities. At the same time, UNL is aware that an employee’s relationships with outside enterprises can give rise to opportunities for personal gain or financial advantage that may be at odds with the obligations the individual assumes as a UNL employee. A conflict of interest (COI) can occur when an employee has competing interests between their UNL role and their interests in outside entities, potentially introducing bias into their judgment, decisions, or actions at UNL. Similarly, a conflict of commitment (COC) can occur when an employee uses UNL resources, such as their paid time, to complete outside work, potentially leading to UNL subsidy of outside activities or employee failure to meet UNL job expectations.

As stewards of public funds and resources, it is critical for UNL employees to transparently disclose information regarding actual, potential, or perceived COIs/COCs. A COI/COC is a situation, not a behavior. Disclosing this information does not mean wrongdoing has occurred. Disclosure allows your supervisor(s) and UNL compliance staff to fairly and independently determine if a conflict exists that requires some form of management. Everyone at UNL is responsible for safeguarding the resources and reputation of the University. The public looks to university-based academic work and research as an independent, unbiased source of information. A COI/COC program that includes active disclosure promotes public trust in UNL as an entity that operates with integrity.

The principles that underscore the importance of disclosure also underly federal, state, and University of Nebraska policies that require disclosure of outside interests and activities.

Report all paid and unpaid outside activities, relationships, interests, and intellectual property for you (and immediate family members) with any outside entity/organization (including foreign institutions, governments, and companies) when they:

1. reasonably relate to, rely upon, and/or utilize your area of expertise, scholarship, and/or university employment (including responsibilities)
2. have the potential to influence your university duties/responsibilities (like research, teaching, clinical, or public service) or
3. involve an external entity that conducts business with NU/UNL

The following matrix is also provided to help further illustrate what does or doesn’t need to be disclosed:

Disclosure Matrix

“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. Essentially, the job responsibilities that you have through your employment/work for UNL.

Immediate family is defined as your spouse/domestic partner, child, ward, parent, brother, sister, grandchild, or grandparent, by blood, marriage, or adoption of the employee. 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.

Your COI/COC Disclosure will be routed to your supervisor(s) and any next level supervisor(s), depending on your UNL role. It will then go to the COI/COC program staff for review. Often, completion of your disclosure is sufficient. In situations where an actual or potential conflict of interest must be managed beyond disclosure, Research Compliance Services will work with you to present your conflict to the Conflict of Interest Committee for review and the possible development of a management plan to mitigate the conflict.

This depends on many factors. Since there are several individuals that are responsible for reviewing these forms, the review can take time, especially if the disclosure is complex or incomplete. Generally, the full review is complete within two (2) weeks to two (2) months.

A conflict of interest may arise when your relationship with an outside entity might appear to bias your judgment in performing your professional responsibilities at UNL.

A conflict of commitment may arise when you engage in external activities or assume external commitments that might appear to compromise your ability to fulfill the responsibilities of your obligations to UNL.

The disclosure you complete in NuRamp fulfills reporting requirements across multiple, separate areas (e.g., Board of Regents policies and research regulations) through a single form. We understand it can seem repetitive or frustrating to add information on one activity into several sections of the form; however, we need to ensure the disclosed information satisfies each of the areas or policies that requires disclosure. This can be difficult to capture at times.

The manner in which the NuRamp disclosure form is built is well ahead of many of our peer institutions. For example, some institutions do not combine the COI/COC disclosure and require employees to fill out separate forms, in separate systems, for these processes.

Nevertheless, we are always working to identify areas of improvement and may be able to make changes in the future that make this aspect of disclosure easier.

No. You may generally not use university resources, funds, personnel, intellectual property (e.g., logos and marks), physical office/lab space, letterhead or confidential or proprietary information in the performance of your outside professional activities.

If you would like to utilize such resources, you must seek university approval. In some cases, approval will not be granted.

In general, no. However, limited personal use of university information systems, including email, is acceptable if you don’t use it for personal financial gain or use it to represent yourself as a “university agent” to an outside entity. It is strongly recommended that you use a personal email address and computer for personal use.

Conflict of Interest (COI) refers to a situation in which a primary interest has the potential to be inappropriately influenced by a secondary interest. COIs can involve non-financial and financial interests.  

It is important to note that a conflict of interest is a situation. It does not mean an individual’s behavior is necessarily biased. Even a perceived conflict of interest, if unmanaged, can compromise the public’s trust in the University.

If the Conflict of Interest Committee determines that one or more of your disclosure entries represents an actual, possible, or perceived conflict of interest, the COI Committee will implement a management plan to reduce, mitigate, and/or eliminate the identified conflict(s). Please see “Management Plans & Oversight” in our A-Z Guidance for more information regarding typical clauses such as disclosure in publications, internal peer review, and safeguards for students.

When conflicts of interest are properly disclosed and managed, it generally does not prevent you from conducting your work. Delays in the ability to conduct work may occur, however, if you do not complete the COI/COC Disclosure and/or training in a timely manner or if you omit relevant interests from the form.

As part of an effective COI/COC program, including adequate review and vetting of outside entities, UNL needs to know the names of each outside entity for whom you are doing work that could overlap in some way with your university responsibilities, to appropriately address any actual, potential and/or perceived conflicts of interest or commitment, including any institutional ones.

Disclosing only your ownership in the consulting company and the time spent on the company’s consulting work (as financial interest and outside professional activity entries, respectively) can lead to difficulty in identifying actual, potential and/or perceived conflicts of interest with respect to university functions (like sponsored research) or just general day-to-day institutional operations (like vendor payment request through procurement).

• For example, if a client of your company decides to sponsor research in your lab, an actual, potential and/or perceived conflict of interest may be created that would otherwise be undetectable but for the proper disclosure of the client in its own separate entry.
• Similarly, if you do not disclose that your consulting company has a work contract with another NU campus, it would be impossible for procurement to know if a conflict existed, which could delay appropriate payments of the work contract.

Thus, it is important that your disclosure includes entries covering each client.

If you collaborate on a PHS and/or DOE funded UNL sponsored research project, but your institution does not maintain and enforce a conflict of interest policy in compliance with federal regulations, UNL may request that you complete the UNL COI Outside Collaborator Form in NuRamp along with training. Additionally, if you are a member of a UNL Research Oversight Committee (e.g., the IRB, COI Committee, SROC, IACUC or IBC) you may also be required to complete a UNL COI Outside Collaborator Form.

To complete the UNL COI Outside Collaborator Form please contact COI staff.

Conflict of Commitment (COC) occurs when the time devoted to external activities adversely affects, or has the appearance of adversely affecting, an employee’s capacity to meet University responsibilities.  

Outside professional activities are defined as external work or business opportunities, paid or unpaid, that are personal and not essential to an employee’s fulfillment of their University job duties. University employees should generally perform outside professional activities outside of their normal university work hours.

UNL encourages ‒ and the Board of Regents bylaws allow ‒ employees (both faculty and staff members) to engage in outside professional activities. Doing so allows you to contribute to the economic growth and development of the state, as well as broaden your experience and keep you abreast of the latest developments in your specialized field―provided such activities do not interfere with your regular university duties or represent a conflict of interest. You may accept temporary or occasional outside employment for professional services when such employment is recommended by your supervisor(s) and compliance staff through your disclosure submission in NuRamp.

There are limitations to the amount of time one can devote to outside activities, please reference the topic below on “limitations or restrictions.”

Such activities include those that further your professional knowledge or expertise or otherwise directly contribute to your role at UNL, such as attending conferences, lectures or continuing education sessions. Volunteer activities for community or charitable organizations or political campaigns or parties also are not included in the definition. See also Category I, COC activities, per the UNL COI/COC policy.

Provided they do not otherwise pose a concern with the UNL COI/COC policy or other university policies, such activities may include consulting, expert witness services, external board service (for either for-profit or not-for-profit entities), or other jobs.

 Some examples of such activities include:

• Serving as a consultant to an individual (or individuals), company, corporation, organization or agency on a project or activity involving UNL
• Employment positions that require a time commitment interfering with your work for UNL and/or exceeding BOR time limitations.
• Legal or expert services for external clients in cases in which UNL is a party or witness
• Accepting or pursuing a business opportunity that you learned of in the course of your employment with UNL, that would also represent an opportunity for the university.

Yes. Pre-approval is required prior to engaging in any outside professional activities (whether compensated or not).

Prior to engaging in an activity which may result in an actual, potential and/or perceived conflict of interest and/or conflict of commitment, if you are a university employee and/or student, you must disclose the activity to your supervisor via the university’s electronic Conflict of Interest and Commitment Disclosure Form (COI/COC) in NuRamp. You must disclose these activities, whether compensated or not, regardless of when they occur (e.g., in summer for nine-month faculty, weekends, evenings, etc.).

Some limitations and/or restrictions apply to the amount of time you can spend on outside professional activities. Specific approval of the Board of Regents is required if you:

(a) Are retained to provide professional services outside the university to an individual person, client, company, firm or governmental agency over a time period lasting more than two years

(b) Accept professional employment requiring more than an average of two days per month during the period of your full-time university employment.

If the outside professional activity exceeds either of these limitations, review and approval by the Board of Regents is required. To comply with these limitations, you may make alternative arrangements in consultation with appropriate, authorized individuals within your college/department. These alternative arrangements may include a reduction in FTE status.

Yes, even if you have a reduction in FTE, you will need to report any outside professional activities that appear to overlap with and/or relate to your university responsibilities. To report your updated FTE status in NuRamp, choose “Other” in Appointment Type and indicate your FTE status (e.g. 50%, 70%, etc.).

After you complete and submit the conflict of interest/conflict of commitment (COI/COC) disclosure form, it is routed to your supervisor(s), next-level supervisor(s) depending on your UNL role, and COI/COC staff. E-mail notifications are sent if revisions are needed and once the form has been approved. The form is active for one year.

The form reviewers consider various questions in their respective reviews, including but not limited to:

1. Has the employee asked to engage in an activity that exceeds the policy limitations of no more than two days/month and/or no longer than two years?
2. Has the employee made satisfactory arrangements to cover all university responsibilities during their absence?
3. Has the employee, in this case a faculty member, engaged in outside professional activities during the current appointment year in excess of the stated limitations?
4. Does engaging in the professional activity advance the skills and abilities of the faculty member, with resultant benefit to the employing unit?
5. Will engaging in the activity be detrimental to the unit or university?
6. Is the employee in good standing and meeting expected standards of performance?
7. Does the activity present a conflict of interest?
   
   

If items are identified that require management, your supervisor(s) should reach out to you to discuss them. In addition, if you wish to engage in an activity that exceeds the stated limitations, someone from your upper-level reviewer/administration will reach out to determine how best to move forward and whether review at the next available Board of Regents meeting will be necessary.

We want to ensure smooth and effective collaboration within the NU system. Collaboration or work associated with another NU campus is encouraged and does not require disclosure, as long as you have your supervisor’s approval and are staying reasonably within the bounds of your institutional responsibilities or obligations to any applicable federal sponsors. Please be cognizant that your primary appointment and responsibilities remain with UNL.

Please note: this answer would be different if you are performing work as an outside activity. For example, if you are consulting at one of the NU system campuses and the work is not part of your institutional responsibilities but is being carried out as an outside activity, this situation would require disclosure.

While there are different ways of approaching these types of situations, based on risk, this is not something that would require disclosure. Primarily, this falls into the “service to the profession” area, very similar to the activities of faculty who engage in U.S.-based grant review. Moreover, the work involving a U.S. institution of higher education and a U.S.-based accrediting body for the purposes of verifying accreditation requirements is a largely benign, normal process.

As a full-time university employee, you may participate in outside professional activities before or after your normal university work hours (e.g., mornings, evenings, or weekends), and this time does not count toward the allowable average of two days per month for outside employment. However, these outside professional activities must be disclosed each year and reviewed for alignment with Category 1, 2, or 3 conflicts of commitment, as defined by the university’s COI/COC Policy.

Consulting is a very common form of outside professional activity. Employees who engage in consulting work should have their consulting activities memorialized in an agreement or contract that, at a minimum, clearly defines the technical scope, intellectual property commitments (if any) and financial terms (among other possible terms and conditions). Any such agreements are between you, in your personal capacity, and the contracting outside entity. UNL is not, and shall not be, a party to any such agreements. Therefore, you are solely responsible for ensuring that the agreement is consistent with your university employment obligations.

You are strongly encouraged to utilize the Addendum to Consulting Agreement as an  addendum to any outside professional services agreements you enter into or plan to enter into. This Addendum helps to clarify, as much as possible, the nature and scope of activities you may be called upon to perform in your engagement outside UNL. The inclusion of this addendum is appropriate regardless of the agreement’s overall time commitment or amount of remuneration.

If the consulting arrangement is not formalized through a written agreement, the addendum should be modified accordingly, dated and signed by both you and a company representative.

As a service to employees, NUtech Ventures can provide advice as to whether your personal consulting agreement is consistent with the university’s intellectual property policies. Additionally, your unit director/head/chair is often the best source of advice regarding your outside professional activities and associated time commitments. UNL Research Compliance Services can advise you on matters of conflicts of interest and commitment and other issues related to personal consulting agreements. Because outside activities, by definition, occur outside of the university, if you have other questions about consulting work (and any associated contracts), you should seek the services of a qualified personal attorney for formal legal advice.

In general, yes. You must report all outside activities that could overlap or relate to your university responsibilities, even if you do not receive direct payment for them. Report any activities, relationships or interests that you have that were not coordinated or negotiated by UNL.

In general, yes. You must report all non-university based outside activities that could overlap or relate to your university responsibilities, even if you do not receive direct payment for them.

In general, you are not required to disclose activities that are not related to your university responsibilities unless the time devoted to these activities interferes with your obligations as an employee.

For example, a faculty member in the Chemistry Department spends weekends judging dog shows; similarly, an employee sells makeup products on the weekends. Because these activities have no overlap with their university responsibilities, they do not require disclosure.

No. You do not need to disclose work you perform for an entity outside of UNL, if you perform the work as part of your university responsibilities.

No. You need to report only service as an officer, director, trustee or public representative for such organizations.

Yes, as an exempt academic-year employee, you must still maintain an active disclosure that includes any activities occurring over the summer, as these still have the potential to create conflicts of commitment and/or conflicts of interest.

Yes. As a part-time university employee, you must disclose your non-university job (whether compensated or not) if the activities associated with that job reasonably relate to or could interfere with your professional expertise, practice of your profession or the duties associated with your job at UNL.

No, you do not need to disclose this situation unless there is some potential or actual overlap with the LLC and your university responsibilities.

No. This situation is similar to an investment account in which other professionals make management decisions for university employees’ investments.

Yes. You should disclose participation in any business enterprise as an owner, partner, officer, supervisor, manager or in any capacity with management responsibilities. Because you still have an ownership interest in the LLC – even in years when no consulting activity takes place – that ownership interest should still be disclosed on at least an annual basis.

As long as the organization is U.S.-based, this is considered a Category 1 activity and does not require disclosure in annual reporting or prior approval and does not count toward your maximum number of days of outside professional activities.

As long as the other university is U.S. based, this is considered a Category 1 activity and does not require disclosure in annual reporting or prior approval and does not count toward your maximum number of days of outside professional activities.

As long as the other university is U.S. based, this is considered a Category 1 activity and does not require disclosure in annual reporting or prior approval and does not count toward your maximum number of days of outside professional activities.

As long as the other university is U.S. based, this is considered a Category 1 activity and does not require disclosure in annual reporting or prior approval and does not count toward your maximum number of days of outside professional activities.