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Disclosure Review Process

Types of Conflict of Interest:

COI disclosures fall into two categories: those without outside interests (all KCOI questions are answered no) and those with outside interests (at least one question is answered yes). If your COI disclosure reports no outside financial interests, the KCOI disclosure system immediately routes it into an “Up to Date” status, and no COI Office review typically occurs.

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.

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.

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 delay of study approval and/or release of research funds.

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