Disclosure Review Process

Types of Conflict of Interest:

COI disclosures fall into two categories:

1. Those who have no outside professional activities to disclose (all KCOI questions are answered no)

• If your COI disclosure reports no outside financial interests, the KCOI disclosure system “auto-approves” the disclosure and provides a NO COI disposition. The COI Office reviews after the fact for errors in reporting.

2. Those with outside professional activities (at least one question is answered yes)

• If your COI disclosure reports outside financial interests, the form is routed to your unit head/chair and Dean for review and then submitted to the COI Office staff, with a status of “Submitted for Review” displayed on your KCOI dashboard. The COI Office will review the disclosure to verify that it is complete. If additional information is required, you will receive an email from COI@umd.edu.

A common misconception is that people think disclosing a potential conflict means there necessarily IS a conflict and that if there is a conflict, they are not allowed to do the activity. This is not the case; the COI Committee is here to help find ways to manage potential, perceived, and/or real conflicts.

Administrative review

Under some circumstances, the Chair of the COI Committee makes the determination with regard to the disposition of the disclosure.

COI committee review

The UMD COI Committee reviews the disclosure and determines what action to take (e.g., accepting or revising the included management plan or suggesting a management plan is required) or requests additional information to make a final decision. The COI Committee also may determine that no action is necessary or request that a best practices memorandum be put into place. If a management plan is required, the COI Committee makes a recommendation to the President. Only the President can approve a COI management plan.

Compliance review

In many cases, current and complete COI disclosures must be verified by various UMD offices before any type of research or sponsored program activity may begin. Those offices may include, but are not limited to, the Office of Research Administration, Institutional Review Board, IACUC, and Export Control. Failure to have a current disclosure on file or to provide additional information requested by the COI Office may result in a delays in study approval, facility use licenses, gifts, and/or release of research funds.
 

The majority of disclosures are resolved within 2-3 weeks, BUT the COI process can take 6-8 weeks depending on how quickly the routing goes through.

Considerations that add time to the review process include:

• Administrative questions requiring additional information or revision and re-routing to chair/dean.
• Timing of disclosure submission. The COI Committee meets monthly (except August) to review disclosures.
  • To be considered for an agenda, the disclosure routing and administrative questions need to be finalized by the 1st of the month.

We ask for your patience as the process does take time. If you have any questions or an urgent disclosure that needs to be resolved, e.g., to set up an award or finalize a facilities use application, please contact COI@umd.edu, and we can try to move your disclosure up in the queue.