The public looks to university research as an independent, unbiased source of information. Because some university researchers also have private interests in entities that contribute to research, the federal government, the state of Nebraska, and UNL require disclosure of financial interests.
UNL requires disclosure of interests that appear to be related to your institutional responsibilities. The following FAQs help to address any questions that you may have about the COI process at UNL:
What is a conflict of interest?
Broadly speaking, a conflict of interest is a situation in which a secondary interest may improperly influence or bias a primary interest. In the sponsored research setting, we are focused on ways in which personal financial interests may improperly influence the design, conduct, or reporting of research.
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 research results.
Who must disclose financial interests?
A UNL COI/COC Disclosure must be completed annually through NuRamp by all UNL faculty, staff, students and affiliates 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. 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.
What financial interests must be disclosed?
Financial interests that reasonably appear to be related to your institutional responsibilities must be disclosed on an annual basis by filing a COI/COC Disclosure via NuRamp. 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 or Department of Energy 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.
What constitutes a significant financial interest that may require management?
Per the federal guidelines for Promoting Objectivity in Research (42 CFR 50 Subpart F), a significant financial interest (SFI) is defined as “A financial interest consisting of one or more of the following…that reasonably appears to be related to the Investigator’s institutional responsibilities”:
- Publicly traded entity: if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
- Non-publicly traded entity: if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or immediate family) holds any equity interest (e.g., stock, stock option, or other ownership interest)
- Intellectual property rights and interests (e.g., patents, copyrights) upon receipt of income related to such rights and interests. NOTE: this does not include intellectual property rights assigned to the Institution and agreements to share in royalties related to such rights via NUtech ventures
To apply the criteria to your own situation, use this FCOI Assessment Flowchart.
Are there exceptions to what must be disclosed?
The following interests are not considered significant financial interests and 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
What are “institutional responsibilities”?
“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.
Who is included in the definition of “immediate family”?
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 for purposes of employment benefits. 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.
Would I need to disclose income received from international universities or non-profit agencies?
Yes. Payments received from entities that are not exempt from the disclosure requirement (see above) must be disclosed.
If part of my salary is funded by a grant, would I need to disclose such a payment?
Funding that is routed through the appropriate University channels (such as the Office of Sponsored Programs) does 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.
What is the disclosure process?
Complete a COI/COC Disclosure via NuRamp prior to engaging in research or any outside activities. Disclose all interests and outside activities related to your institutional responsibilities at least annually.
How do I complete the COI/COC Disclosure?
Login to NuRamp using your UNL 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, contact the COI Coordinator (2-6907, or, unlcoi@unledu) in Research Compliance Services.
What is the review process?
Your COI/COC Disclosure will be routed to your department chair/director and dean. 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 to develop a management plan.
How are conflicts of interest managed?
Dependent on information disclosed, management plans can include, but are not limited to, disclosure in publications and presentations, internal peer review, or safeguards for students.
What should I do if my financial interests change prior to the expiration of my COI/COC Disclosure?
Your COI/COC Disclosure is valid for one year from the approval date. If your financial interests or circumstances change during the annual reporting period, a Change Request Form 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.
Can a conflict of interest delay or prevent me from doing research?
When conflicts of interest are properly disclosed and managed, it generally does not prevent you from conducting research. Delays in the ability to conduct research 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.
Do I need to complete a COI/COC Disclosure even if I do not have any outside interests related to my research activities?
Yes. 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 to disclose.
How should individuals that are not affiliated with UNL disclose outside interests?
Contact the COI Coordinator (472-6965, or firstname.lastname@example.org) in Research Compliance Services to first ensure that you need to file a disclosure with UNL.
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 Collaborator Interest Reporting Form and CITI conflict of interest training.
Are there penalties for not updating my COI/COC Disclosure within 30 days of a change in financial interests?
Maintaining an accurate and up-to-date COI/COC Disclosure is crucial in ensuring that UNL complies with state and federal reporting regulations. Failure to update your disclosures 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.
What happens if I disclose “All No,” in my COI/COC Disclosure?
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 must follow up to ensure you complete a change request in order to ensure you have completed disclosure in accordance with federal and/or University policies. 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.