Policy Updates 2024-2025

The principles that make a robust UNL COI/COC program important are also of significant importance to the University of Nebraska (NU) Board of Regents, as well as federal research sponsors. Updates to the UNL COI/COC Policy in 2024 align the policy with NU Board of Regents policies and NU Executive Memorandum 36, as well as ensuring the policy continues to meet the requirements of federal research sponsors.

• Updates to the UNL COI/COC Policy include
  • Changes made to more clearly define COI/COC areas and expectations and expand policy language to be more inclusive of non-research areas, including an expansion of employee types expected to complete annual disclosures
  • Changes made to meet new federal sponsor requirements such as those of the Department of Energy (DOE) and National Science Foundation (NSF)
  • Changes to expand the Conflict of Interest in Research Committee, to one general COI Committee that focuses on all areas, not just research

In Spring 2024, a small implementation group was formed to make plans for communication about the updated policy requirements to the campus. Representatives from the Office of Research and Innovation (ORED), the Executive Vice Chancellor’s Office, Business & Finance, the Institute of Agriculture and Natural Resources (IANR), and University Communications comprise the implementation group. As part of this intentional process to make a broader set of employees aware of the annual disclosure requirements, several procedural and informational updates have been made, which include:

• Updates to the disclosure form in NuRamp
  • Training information is now included in the NuRamp disclosure itself so that all those disclosing receive training. This was completed to expand the focus from former completion of CITI COI in research training which only reached certain areas of the campus. This will also significantly reduce time for training completion and those that previously utilized CITI COI training will no longer have to do so.
• Updates to webpages to reflect the expansions detailed above
• Development of additional informational resources, such as tip sheets and FAQs

The COI implementation group will be communicating with leadership in each respective area listed below ahead of the time window listed. Plans will be made for communicating to area employees to help inform those expected to complete an annual disclosure who have not previously done so. All those that already have an approved-active disclosure do not need to take any action. Only those who have never completed a disclosure or have an expired disclosure will be part of this implementation process.

Summer 2024

• June 2024
  • Business and Finance
  • Office of Diversity and Inclusion
  • Office of Research and Innovation

• July 2024
  • Student Affairs

• August 2024
  • Chancellor’s Office

 Fall 2024

• September 2024 (after labor day)
  • College of Journalism and Mass Communications
  • Hixson-Lied College of Fine and Performing Arts
  • University Libraries

• November 2024
  • College of Arts and Sciences
  • Executive Vice Chancellor’s Office

 Spring 2025

• February 2025
  • College of Architecture
  • College of Business
  • College of Engineering
  • College of Law
  • Raikes School

• April 2025
  • Institute of Agriculture and Natural Resources
  • College of Education and Human Sciences

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 a 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.

COI/COC administrators and other stakeholders have recognized that confusion has been occurring at UNL regarding disclosure needs. While Board of Regents policies and by-laws have long expected disclosure from many employees and some students (e.g., researchers, managerial/professional, signature authority/purchasing) no singular entity on campus has been managing or communicating these processes systematically. Additionally, only certain employees or students involved in funded research on campus have been clearly expected to disclose and complete training requirements. This left gaps for both disclosure and understanding (training) on campus. Administrators, employees, and students struggled to understand when disclosure was necessary, with many disclosing or completing supervisor review of disclosures without receiving training.  

Through the UNL COI/COC Policy updates, enhanced informational resources, and training incorporation into the annual disclosure in NuRamp, we are hopeful that the campus can move toward better understanding of these requirements and ultimately timely disclosures of potential conflicts that could impact university work. 

Great! You do not need to change anything. Please ensure you continue to follow NuRamp prompts for completing your disclosure annually (whether you have anything to report or not). If you have previously completed our COI in Research Training through CITI, that will no longer be required and instead, the training information incorporated into the annual disclosure in NuRamp will be accepted as meeting training requirements as soon as you have completed your next annual disclosure.  

Disclosure is completed in the NuRamp system, utilizing your UNL TrueYou credentials: https://nuramp.nebraska.edu/login

If you have never logged into NuRamp or completed a disclosure previously, please see our resources listed below. The Video Resources in particular, provide short videos that describe various aspects of starting and completing a disclosure.