U-M Outside Interest Disclosure Process
As a researcher at the University of Michigan, you are expected to disclose any financial or management interest in an outside company or other entity as it relates to your employment. Your disclosure ensures that you and U-M are compliant with the federal and state regulations designed to safeguard objectivity in research.
The University’s annual disclosure review begins July 1 with each new fiscal year.
- If you have, or are applying for, PHS funding you must disclose outside interests per Public Health Service financial conflict of interest (FCOI) regulations. [NIH pdf]
- To learn about your unit’s disclosure guidelines and instructions, see the Conflict of Interest/Conflict of Commitment Unit Implementation Policy on the Provost web site.
- For detailed information about the policies and principles behind conflict of interest, including the U-M review process and common examples, see the U-M Conflict of Interest web pages.
Using the M-Inform Disclosure System
M-Inform is the university’s online disclosure system. To access M-Inform go the Wolverine Access > Faculty & Staff menu at: http://wolverineaccess.umich.edu. As an employee, you use this system to complete and submit the disclosure form(s). This may include reporting that you do not have outside interests related to your employment or reporting an interest in more than one entity.
Each disclosure is reviewed by your unit and, if applicable, by a U-M Conflict of Interest Office (COI-OVPR or COI-MED) to ensure compliance with federal, state, and university policies.
If a conflict of interest is identified upon review, a COI Office works with you to manage the conflict to mitigate impact on your research.
M-Inform Training & Resources:
- Not sure what type of activity needs to be disclosed?
Use the Outside Interest Decision Tree (shown right) to help decide. Click the image to open the decision tree.
- Procedure: Submit/Update an Outside Interest Disclosure
[PDF] M-Inform instructions to add, update, and remove outside interest disclosures
Unit Assistants (discloser proxy):
- Procedure: Prepare/Update a Disclosure for Another
[PDF] M-Inform instructions for proxies
- Procedure: Review an Outside Interest Disclosure
[PDF] M-Inform instructions to review and approve disclosures
- U-M Reviewers: 10 Points to Consider
[PDF] U-M guidelines for those who review M-Inform disclosures for their unit
- Procedure: Maintaining Department Information in M-Inform
[PDF] Instructions to assign M-Inform roles (e.g., unit reviewers for a unit or individual) and send M-Inform reminder emails to disclosers.
- Sample of the M-Inform Disclosure Questions
PDF, To assist disclosers in your unit with their outside interest disclosure in M-Inform. DO NOT use to submit disclosure information.
Non-UM Affiliate Disclosure Process
Individuals not affiliated with (i.e., not employed by) the University of Michigan may be required to disclose outside interests related to the proposed research when listed as an investigator on:
- A subcontract to another organization for a U-M project funded by a sponsor following the PHS financial conflict of interest regulations.
- An IRB application for a U-M human subjects study.
Non-UM affiliates complete and submit the Financial Interests Disclosure Form for Investigators Not Affiliated with U-M [Word doc], as applicable. Follow the instructions provided by the U-M project or study team to submit the completed disclosure form to the university.
Start-Up Company Disclosure Process
U-M employees, students, or trainees must maintain a Company Profile in M-Inform if they develop a start-up company that does the following:
- Options, licenses, distributes, or commercializes intellectual property (e.g., technology) developed at the university, and/or
- Does other research-related business with the university (e.g., sponsors the research)
Your company’s profile information assists the COI Offices in their review and management of potential conflicts of interest. The appropriate COI Office initiates a Company Profile when a new company is identified via the COI question on the proposal application form (PAF) in eResearch or by the U-M office of Technology Transfer.
For instructions on completing the M-Inform Company Profile, see the Update Your Company Profile procedure. For questions, contact the U-M COI Offices at COI.Support@umich.edu.
See the links below, plus:
- For assistance with completing or reviewing disclosures, contact your unit (listed on the help page).
- For technical assistance with M-Inform, contact the ITS Service Center at 4-HELP (764-4357).
- For U-M disclosure and COI policy questions, email the COI Committees for advice at COI.Support@umich.edu.