Conflict of Interest Frequently Asked Questions

What is considered a conflict of interest at UMB?

When an individual involved in UMB research has any financial interest in the outcome of the research, the subject of the research or the commercial sponsor of the research, the situation must be disclosed and reviewed for potential conflict of interest issues.

What must I do if I have a conflict of interest?

Details of the financial interest(s) generating the conflict of interest and the potentially affected research must be disclosed to the Conflict of Interest Officer and/or the Institutional Review Board (for research involving human participants), as appropriate. If the circumstances meet the criteria of a financial conflict of interest as defined by the Maryland Public Ethics Law and USM policy, then an exemption must be requested of, and granted by, the President of UMB in order for the financial interest to be allowed.

Are there special regulations when NIH research is involved?

NIH policy (located at 42 CFR Part 50, Subpart F – http://grants.nih.gov/grants/compliance/42_CFR_50_Subpart_F.htm) requires grantee institutions such as UMB to report on “significant” financial interests of investigators (and their spouse and dependent children) where the financial interests meet certain threshold amounts; and where the financial interests would reasonably appear to be affected by the research supported by the NIH or where the financial interests are in an entity whose financial interests would reasonably appear to be affected by the research supported by the NIH.  The NIH defines “significant” as more than $10,000 in payments from an entity over a 12-month period, more than $10,000 in equity in an entity, or more than 5% of the total equity in an entity.

Further information on the NIH conflict of interest policy may be found at: http://grants.nih.gov/grants/policy/coi/index.htm

How is consulting or paid speaking related to conflict of interest?

If the consulting or speaking is for the commercial sponsor of the research, then the individual must disclose the potential conflict of interest in addition to obtaining prior approval and otherwise complying with the USM and UMB policies on consulting. If the consulting or speaking is not for the commercial sponsor of the research, then only the consulting policies apply.