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  • Disclosures - When in doubt, disclose.
  • COI/COC Policy applies even if you only have a part-time appointment.
  • All faculty and staff are required to disclose at least annually.
When to Disclose
  • Other times a disclosure is required:
    • New to UMD: Within 30 days of being hired at the University, even if there are NO activities to disclose
    • Prior to engaging in a new Outside Professional Activity 
    • When Submitting a Proposal: Proposals to federal agencies (e.g., PHS, NIH, NSF, USDA-NIFA, DOE, NASA, ARPA-E) or Maryland Industrial Partnerships (MIPS) require disclosure at the time of submission even if there are NO activities to disclose. The disclosure is required, not the review and disposition. The Disclosure must be cleared—reviewed, dispositioned, and managed as needed before AWARD monies can be released.
      • Note: A new disclosure is not required for every proposal; however, there must be an up-todate inTERP disclosure on file, i.e., inTERP disclosure less than a year old and/or updated if there have been changes. Researchers should review their disclosure and update as needed.
      • Example: A researcher disclosed in July 2024 for an NSF proposal submission. In January 2025, they submitted a new proposal to NIH. A new disclosure is only required if there are changes in their outside activities between July and January. If there have been no changes, the July 2024 disclosure complies with the requirement to have an up-to-date disclosure on file.

    • Within 30 Days: Updates required on a rolling basis within 30 days of acquiring (or becoming aware of) a new significant financial interest or beginning a new outside activity

       

    • Be transparent in the disclosure: More details = fewer iterations.

 

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