The public looks to university-based, academic work and research as an independent, unbiased source of information. Because some university employees also have private interests in or involving entities that contribute to research or other academic pursuits, the federal government, the state of Nebraska, and UNL require disclosure of such interests and/or outside activities.
UNL requires disclosure of all paid and unpaid outside activities, relationships, interests, and intellectual property with any outside entity/organization (including foreign institutions, governments, and companies when those activities:
- reasonably relate to, rely upon, and/or utilize your area of expertise, scholarship, and/or university employment (including responsibilities),
- have the potential to influence your university duties/responsibilities (like research, teaching, clinical, or public service)
- involve an external entity that conducts business with NU/UNL
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.
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.
Who must disclose financial interests?
In accordance with NU Executive Memorandum 36, A UNL COI/COC Disclosure must be completed at least annually through NuRamp by
- 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.
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?
You must disclose financial interests that stem from activities that:
- reasonably relate to, rely upon, and/or utilize your area of expertise, scholarship, and/or university employment (including responsibilities)
- have the potential to influence your university duties/responsibilities (like research, teaching, clinical, or public service) or
- involve an external entity that conducts business with NU/UNL
You disclose these financial interests via UNL’s annual COI/COC Disclosure form in NuRamp. Note: you only need to disclose financial interests that are active or that you have received within the past twelve (12) months (unless you failed to disclose the financial interest in the appropriate prior disclosure – in that case you will need to include the financial interest in your most recent disclosure).
Financial interests include, but are not limited to:
- Remuneration, consulting income, royalties, salary, in-kind exchanges, or other payments you receive outside the University of Nebraska system
- Ownership interests (e.g., equity, stocks, stock options, bonds or other ownership interests) in entities that trigger any of the above three numerical points.
- 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 and/or Department of Energy (DoE) awarding agency, sponsored or reimbursed travel must be disclosed
Such financial interests may 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 UNL policy and 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, visit the FCOI Assessment Flowchart found HERE.
Are there exceptions to what must be disclosed?
You do not need to disclose the following financial interests:
- Interests that do not reasonably appear to relate to, rely upon, and/or utilize your area of expertise, scholarship, and/or university employment (including responsibilities)
- Interests that do not have the potential to influence your university duties/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
- Financial interests in mutual funds, retirement funds, or similar investments where you do not control the investment decisions within the portfolio at the level of specific companies
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. Essentially, the job responsibilities that you have through your employment/work for UNL.
Who is included in the definition of “immediate family”?
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.
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, in your personal capacity, 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.
Even if you don’t have anything to disclose, you are still required to complete the annual disclosure. It’s quick and easy; when you don’t have anything to disclose, once you fill out and submit your disclosure, you’ll receive an automated approval notice!
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 staff (2-6965 or unlcoi@unl.edu) in Research Compliance Services.
What is the review process?
Your COI/COC Disclosure will be routed to your supervisor(s): department chair/director and dean. It will then go to the Conflict of Interest staff for review of financial interests and, if applicable, to your appropriate vice chancellor-level reviewer for review of outside activities. 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.
How long does the COI review process take?
This depends on many factors. Since there are several individuals that are responsible for reviewing these forms, there can be delays, especially if the disclosures are complex. Generally, the full review is complete within two (2) weeks to two (2) months.
How are conflicts of interest managed?
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.
What should I do if my financial interests change prior to the expiration of my 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 or other activities?
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.
Do I need to complete a Disclosure even if I do not have any outside interests related to my 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?
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 by phone: (402) 472-6965 or email: unlcoi@unl.edu.
Are there penalties for not updating my 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 or other activities 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.
