Policy Updates 2024-2025

COI/COC Policy Updates 2024-2025

This page has been created to communicate and provide resources to the UNL campus community regarding implementation of updated COI/COC policy and procedures. COI/COC disclosure and management have been an expectation of many UNL employees, for many years. If you are actively completing an annual disclosure already, nothing additional is required; you may find the additional resources informative and helpful. A more intentional and focused process is being implemented in 2024-2025 to ensure communication and resources about these requirements reach all of the necessary areas of the campus.

Why is a COI/COC program important?

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 promotes public trust in UNL as an entity that operates with integrity.

What are the policy updates?

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

Plans for campus implementation of policy updates

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 Economic Development (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

Intended implementation timeline

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 Economic Development
  • 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

Who is required to complete a COI/COC Disclosure?

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).

Who does NOT need to complete a COI/COC Disclosure?

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.
I’ve never been required to disclose before, what has changed?

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. 

What if I’ve already been disclosing?

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.  

Where do I complete 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.


We recognize that the disclosure and/or these requirements may be confusing. We have created the following resources to help guide you through this process.

If you are still unsure about disclosure or have questions, please do not hesitate to contact COI staff in the Research Compliance Services Office: unlcoi@unl.edu or 402-472-6965