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.
Using the M-Inform Disclosure System
|M-Inform is the university’s online disclosure system. 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 review committee (UMOR-COI or MED-COI) to ensure compliance with federal, state, and university policies.
If a conflict of interest is identified upon review, the COI committee works with you to manage the conflict to mitigate impact on your research.
Log into M-Inform from the Faculty & Staff menu on Wolverine Access: http://wolverineaccess.umich.edu
Links to Federal, state, and U-M COI policies
Applying for or have PHS funding? You must disclose outside interests per Public Health financial conflict of interest (FCOI) regulations.
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 an Outside Interest Disclosure
[PDF] M-Inform instructions to add, edit, and remove outside interest disclosures
- Procedure: Update Your Outside Interest Disclosure
[PDF] M-Inform instructions to locate and open your disclosure to make changes when it’s in various states of completion.
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.
COI Attestation Process in eResearch Applications
As a Principal Investigator (PI) or a study team member, completing a conflict of interest statement is a required part of the eResearch processes to:
- Submit applications for sponsored funding proposals via the proposal approval form (PAF)
- Accept a study team role on, or submit IRB applications for, human subjects studies (HUMs)
- Approve draft subcontract (SUBK) agreements
- Submit unfunded agreements (e.g., material transfers) related to proposals or awarded projects
This attestation is not equivalent to completing an outside interest disclosure in M-Inform. In eResearch applications you will see text reminding you to disclose any outside interests related to the research activity.
The eResearch IRB application (HUM) is integrated with M-Inform in that the U-M PI or study team member sees their disclosure status and a link to M-Inform as part of the COI statement. Per U-M and HRPP policies, you are required to disclose in M-Inform if you have an outside interest related to the HUM and you do not have a current disclosure in M-Inform. If you have a current disclosure in M-Inform, you are expected to update that disclosure when an outside interest applies to a new HUM; or amend an active HUM (and your current disclosure) when a new related outside interest arises or a change occurs to an existing related outside interest. See the Discloser procedures for instructions.
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.