Conflict of Interest Guidance and Proposal Requirements

Conflict of Interest (COI) is a legal term that encompasses a wide spectrum of behaviors or actions involving personal gain or financial interest. Under University policy, the term "conflict of interest" denotes situations in which a member of the University community is in a position to gain personal benefit (broadly construed) or financial advantage arising from their University position, either through outside professional activities or through their actions or decisions at the University, including research, administrative, or educational activities. Because University employees are also State employees, the Maryland State Ethics Law governing conflict of interest also applies.

Conflicts of interest are not necessarily negative, nor do they all require management plans. Many times all that is needed to protect the investigator and the University is the disclosure of ownership/equity in a company. In order to ensure all Investigators are aware of their responsibilities and potential liability, BSOS has enacted certain COI requirements for research proposals.

In November 2021, BSOS hosted a forum on Conflicts of Interest presented by members of the Office of the Vice President for Research compliance offices and members of the BSOS Dean's Office. You can watch that forum here. The video is available to anyone at UMD. Undergraduate students may request access but should do so using their @terpmail.umd.edu address so it is clear they are UMD students.

COI Requirements for proposals routing through BSOS:

Principal Investigators and Co-Investigators submitting proposals through BSOS must have completed two tasks related to Conflict of Interest (COI) disclosure and mitigation. This requirement applies to all investigators: including students who are Co-Investigators and individuals from other colleges within UMD if a BSOS department or center is the lead unit.

  • The first requirement is that all PIs and Co-Is must complete the CITI Program’s COI module and, upon completion, upload their certificate of completion at the link below so the Dean’s Office has the certificate on file. The certificate is valid for 4 years. If you are already certified there is no need to retake the course until your certification expires, simply upload your certificate to the Dean’s Office portal. More information on CITI is below.

UPLOAD YOUR CITI CERTIFICATE OF COMPLETION HERE

  • The second requirement is that all PIs and Co-Is must read the UMD Policy and Procedures on COI and initial at the marked spaces in the policy. The initials are being collected via Adobe Sign so once this is completed and submitted there is no other action necessary.

READ AND SIGN THE COI POLICY HERE

If at any point during this process you have questions, please contact Jean McGloin or Rebecca Hunsaker. For more information about Conflicts of Interest, including disclosure forms, please visit the VPR’s website on Conflict of Interest.

The BSOS Dean’s Office will not route proposals to ORA unless and until all Investigators have completed these steps.

 

For investigators on proposals to PHS agencies (which includes NIH and CDC), the Department of Energy, and the National Science Foundation a Conflict of Interest disclosure is also required. This is a Federal requirement, not a campus or BSOS requirement. A disclosure must be filed whether or not there is anything to disclose. For more information on how to complete this disclosure, see the COI website. If a disclosure is not filed at the time of proposal, the award set-up can be delayed while a disclosure is reviewed and adjudicated. NASA is likely going to implement a similar requirement with their next NASA Grant and Cooperative Agreement Manual (GCAM) which comes out in November 2023.

Per the COI Committee FAQs, the COI Committee typically meets the 2nd Wednesday of the month. Disclosures must be completed and routed to the COI office by the first of the month for inclusion in that month's agenda. (This includes review/approval by the Dean's Office.)

 

CITI Program Information:

  1. Go to the main CITI website at: https://about.citiprogram.org
  2. Click "Log In" in the upper right corner.
  3. Choose "Log In Through My Organization," and begin typing "University of Maryland" in the text box. Choose "University of Maryland College Park" from the resulting drop-down menu option. Click "Continue to SSO Login / Instructions." This will prompt the CAS Login screen and the University Multi-Factor Authentication.
  4. Click "View Courses."
  5. If you do not have the Conflict of Interest Mini Course in your course list, scroll to the bottom of the page and click "add a course." To access the COI Mini Course answer "yes" to question 5. For other questions, answer at your discretion based on your situation and interest in other courses. This will load the COI mini course, which has three modules you need to successfully complete.
  6. Upon completion of the COI mini course you will need to download your certificate and upload per the instructions above. To access and save your CITI certificates log in to your CITI Program account and click “My Records.” You will see a print option next to completed courses, which you can click to download a completion report as a .pdf file.
  7. Instructions for navigating CITI are here (https://support.citiprogram.org/s/article/updated-guide-to-getting-started?r=123&ui-knowledge-components-aura-actions.KnowledgeArticleVersionCreateDraftFromOnlineAction.createDraftFromOnlineArticle=1#Affiliations)