Announcing Updated Research Policies and Disclosure Deadline

A Message from Vice President for Research:

Dear University of Maryland Campus Community:

I write today to share some important updates to University policies and processes related to conflicts of interest, conflicts of commitment, and consulting.

As many of you are aware, the federal government is increasingly focused on mitigating risks of technology misappropriation and undue influence in the U.S. research and development enterprise. In a prior message, I detailed the reasoning behind this focus, and today I’m happy to announce that the University of Maryland has updated many of its research-related policies and practices to ensure full compliance with federal expectations. 

To ensure all University researchers are in compliance with the “disclose to propose” requirement, effective October 1, 2025, any proposals where the researcher does not have a current inTERP disclosure will be placed on COI Hold and will not be submitted by ORA. A proposal deadline will not negate this requirement.  Holds will only be lifted upon disclosure completion or with a formal Dean-requested exception approved by the Vice President for Research.  This will apply to all proposals for all external funding entities.  While some funding agencies already have a ”disclose to propose” mandate in place, requiring this of all proposals is critical to ensuring consistent implementation of this requirement.

In this message, I will address the following key points related to UMD’s policies:

• The federal “disclose to propose” mandate requires all researchers, including PI’s, Co-I’s, and Key Personnel, have a current disclosure of outside activities and financial interests on file with their institution before submitting a proposal for funding;
• How our COI/COC Policy applies to GRAs who are specifically named in the proposal and/or working on a sponsored project;
• Consulting for part-time faculty and staff; and
• The new Disclosure and Conflict Management Guidelines. 

Further details on these key changes are provided below, and I encourage everyone to review the revised policies now posted on the University Policies website.

Key Changes to the COI/COC Policy

The University of Maryland Policy on Conflict of Interest and Conflict of Commitment (II-3.10[A]) has been revised and restructured to enhance understanding and to implement several key federal regulations. The revised policy:

• Implements the “disclose to propose” mandate that requires all researchers to disclose outside activities and financial interests to their institution before submitting a proposal for funding, in alignment with federal laws and regulations.
• Expands this policy to include GRAs, who are known at the time of proposals or when known after the award is made.
• Requires all University full-time and part-time faculty and staff, as well as all GRAs working on sponsored projects, to submit a disclosure:
  • Within 30 days of joining the University or the sponsored project,
  • Prior to taking on a new outside activity or financial interest, and
  • Within 30 days of a change to an existing disclosure or annually if no changes are made.
• Addresses requirements prior to proposal and prior to working on a sponsored project.
  • Prior to submitting a new proposal for funding, key personnel, including all investigators named in the proposal, must have an up-to-date disclosure on file with the University through inTERP; and
  • Prior to beginning work on a sponsored project, all University employees and GRAs must have an up-to-date disclosure on file with the University through inTERP.
• Explains how Maryland State Ethics Law applies to University Employees, outlining specific cases that would constitute a conflict of interest or conflict of commitment.
• Clarifies the scope of institutional responsibilities for full-time and part-time faculty and all staff, and sets expectations for ensuring that any outside activities do not interfere or conflict with these responsibilities.

Key Changes to the Consulting Policy

The University of Maryland Policy on Consulting (II-3.10(E)) has also been revised to implement federal regulations and policies.  In the process, the policy has also been updated to reflect principles and decisions of the Research Council in its recent work on reviewing the interim policy. The revised policy:

• Addresses part-time faculty and staff, pro-rating the number of allowed Consulting days for part-time employees according to their appointment.
• Clarifies to whom it applies; all exempt staff and faculty with appointments of 50% FTE or greater are subject to the policy, and non-exempt staff, graduate students, while all employees who are less than 50% FTE are not subject to the policy.
• Emphasizes the “disclose to propose” requirement by federal agencies, whereby researchers must disclose all outside activities, including paid or unpaid consulting, to the University at the time of proposal submission.
• Clearly states the expectation that all Consulting activities be reported on current & pending (other) support, which is required by law.
• References the new inTERP disclosure system processes.
• Outlines the unit head’s and next-level administrator’s roles in decision-making around Consulting, including issues such as determining what constitutes professional service and approving requests for banking Consulting days.

Information on Disclosure Guidelines and Process via inTERP

The COI/COC Policy and Consulting Policy are supported by new Disclosure and Conflict Management Guidelines, developed and implemented by the Disclosure Office, and overseen by the COI Committee.  These Guidelines provide comprehensive instructions to users, explain important nuances of the new disclosure process, and provide examples and links to more information from the University and federal agencies.  The Guidelines will be updated by the Disclosure Office as changes to the process or to federal regulations and funding agency guidance arise to ensure issues are addressed more quickly than policy changes.

Technical Revisions to Other Related Policies

In addition, technical updates have been made to the University’s policies on financial conflicts of interest, organizational conflicts of interest, and institutional conflicts of interest, in order to align them with the new COI/COC Policy and inTERP process. 

• University of Maryland Procedures on Financial Conflicts of Interest in Public Health Service Funded Research -- II-3.10(C)
• University of Maryland Policy on Organizational Conflicts of Interest -- II-3.10(F)
• University of Maryland Policy on Institutional Conflicts of Interest -- X-14.00(A)

While federal regulations, policies, and laws are continually changing, these changes ensure that the University is taking necessary steps to comply with federal and state requirements; this is especially important given that the U.S. Department of Justice announced it would increase its use of the federal False Claims Act to ensure compliance with various obligations.  As University researchers, all faculty, staff, and GRAs on sponsored projects should take some time this summer to familiarize themselves with their new responsibilities under the policies and to disclose all outside activities and financial interests in inTERP, so they are ready to submit proposals when the time comes.

I extend my gratitude and thanks to the President, the Research Council, the Division of Research staff and faculty, especially those involved in the development of these policies, the Disclosure Office team, who have been instrumental in the implementation of inTERP, and everyone across campus who worked to make these changes possible.

Sincerely,

Gregory F. Ball

Vice President for Research