Conflict of Interest Frequently Asked Questions


What is considered a conflict of interest at UMB? 

 Individual conflicts of interest fall under two UMB policies.

  • Procedures Implementing Board of Regents Policy on Conflicts of Interest in Research or Development:
    • Conflicts of Interest in Research and Development occur when a UMB employee has any financial relationship with or financial interest in an entity that has a direct interest in the outcome of research at UMB.
    • A Conflict of Interest may also occur in matters concerning close family members, in particular a faculty or staff member applying for or having a funded grant or contract that supports a family member. The Maryland State Ethics Law generally prohibits UMB faculty or staff employees from taking action in matters concerning their relatives, or from using a UMB position for the financial gain of their relatives.
  • UMB Policy and Procedures on Financial Conflict of Interest to Promote Objectivity in Public Health Serve – Funded Research:
    • Conflicts of Interest under PHS regulations occur when a researcher, participating on PHS-funded research, has a significant financial interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research. PHS regulations also concern subrecipient investigators. For non-UMB employees participating on UMB PHS-funded research, UMB is required to ensure that those employees also are compliant with the regulations.

What must I do if I believe I have a potential conflict of interest under UMB’s CoI policy in research and development? 

Contact the CoI Officer to make sure there is a conflict of interest requiring disclosure and campus review.

Details of the financial interest generating the CoI and the potentially affected research must be disclosed to the CoI Officer and/or the Institutional Review Board (for research involving human participants), as appropriate.

If there is a CoI under USM policy and Maryland Public Ethics law, you will be required to submit a disclosure form to request a CoI Exemption and have it reviewed by your supervisor, division head, department chair, dean’s office, and the CoI officer.

If approved, you will be granted a CoI exemption from UMB’s president that includes conditions under which the exemption was granted.

May I proceed with my financial interest and my research while my CoI exemption request is being reviewed? 

No. An employee’s relationship with an entity with a direct interest in the outcome of the research is prohibited unless exempted by the president of the University.

What do I need to do if I am a consultant or participating on an advisory board? 

Under the University’s policy on Consulting and Other External Activities, prior approval is required. Requests for approval should be directed to the dean or designee.

If prior approval is secured, and your external activities are with an entity which also has a direct financial interest in the outcome of your research at UMB, then you must contact UMB CoI Officer to disclose these activities and request a CoI exemption from the President of UMB.

What are the new U.S. PHS regulations? 

The new 2012 PHS regulations require anyone participating in the design, conduct, or reporting of PHS-funded research to submit a Significant Financial Interest (SFI) Disclosure Form, even if there is nothing to disclose, and to complete training on the regulations every four years. Annual reports for SFI disclosure forms also are required, even if there is nothing to disclose or there are no further updates.

How do I complete UMB’s PHS online training and submit a SFI disclosure form? 

The link for UMB’s PHS online training and SFI disclosure form is located on the CoI Office’s web page under the PHS heading.

There is a CoI Officer in my school; who do I speak to? 

Your school may have a CoI Officer in place for handling CoI concerns within your school.

UMB’s CoI Officer is the designated official under UMB’s CoI policies to review and manage financial conflict of interest matters for all affected UMB employees.

Your school’s CoI Officer collaborates with UMB’s CoI Officer, and it will be necessary to speak to both.