UNL Conflict of Interest & Commitment Policies (Comprehensive PDF)
This policy is specific to UNL and outlines requirements for compliance. It has been updated to maintain compliance with federal regulations and became effective August 24, 2012. The policy has now also been updated to meet new PHS, DOE, and other clarifications from the NU Board of Regents, effective June 1, 2024.
A comprehensive policy document is linked above. In addition, each section of the policy is also individually linked below for ease of reference.
1.0 Scope and Policy Statement
2.0 Definitions
3.0 Institutional Responsibilities
4.0 Training
5.0 Reimbursed and Sponsored Travel
6.0 Conflicts of Commitment/Outside Activities
7.0 Institutional Conflicts of Interest
8.0 Organizational Conflicts of Interest
9.0 Individual Conflicts of Interest
10.0 Conflict of Interest Committee
11.0 Process For Managing, Reducing, or Eliminating Conflicts
12.0 PHS/DOE Subawardees/Subcontracts
13.0 Start-Ups or Other Ventures
14.0 Conflicts of Interest Involving Human or Animal Subjects
15.0 Monitoring, Noncompliance, Restrospective Review, Mitigation Report, and Appeals
University of Nebraska Board of Regents Conflict of Interest and Conflict of Commitment Policy (BOR Policy 3.2.8)
This policy outlines principles for all NU campuses regarding COI and conflict of commitment. While addressed in the same Board of Regents policy, oversight of conflict of commitment is the responsibility of each administrative unit (Academic Affairs, Institute for Agriculture and Natural Resources or Student Affairs, etc.) as well as Research Compliance Services. Conflict of commitment policies apply to a broader range of individuals at UNL and not just sponsored research investigators. See policy starting on page RP 99.
University of Nebraska System Wide Executive Memorandum No. 36
Executive Memorandum #36 requires certain individuals to complete a COI/COC Annual Disclosure form, even in the absence of an actual, potential, or perceived conflict of interest or conflict of commitment. See EM 36 for a complete list of who needs to submit a COI/COC Annual Disclosure form.
U.S. Public Health Service Final Rule: Promoting Objectivity in Research
The Public Health Service (PHS) first established rules regarding conflict of interest in 1995. The revised regulation was released in 2011 and became effective August 24, 2012. Currently, UNL is only applying the stricter requirements to researchers seeking funding from PHS and those funding agencies that have decided to adopt these regulations.
Department of Energy Interim Conflict of Interest Policy Requirements for Financial Assistance
The Department of Energy (DOE) released an interim conflict of interest policy on December 20, 2021. The new policy imposes stricter rules regarding conflict of interest, similar to the PHS Final Rule. UNL is applying the stricter requirements to researchers seeking funding from the DOE.
Related Policies
The following policies are not specific to conflicts of interest and apply more to conflicts of commitment. However, because the COI/COC Disclosure covers both outside activities and conflicts of interest you should be aware of this guidance in the completion of your employment and institutional responsibilities.
