Conflict of Interest (COI)
The University of Michigan defines a conflict of interest (COI) as:
A situation where a faculty or staff member’s personal, professional, commercial, or financial interests or activities outside the University have the possibility of:
- compromising the faculty or staff member’s judgment;
- biasing the nature or direction of scholarly research;
- influencing the faculty or staff member’s decision or behavior with respect to teaching and student affairs, appointments and promotions, uses of University resources, interactions with human subjects, or other University matters; or
- resulting in a personal or family member’s gain or advancement at the expense of the University.
About the COI Research Compliance Program
U-M follows several federal, state, and University policies and guidelines that govern the disclosure of an outside activity, relationship, or interest (“outside activity”), and the management of personal conflicts of interest (COI) and conflict of commitments (COC) in research. The COI research compliance program provides oversight of, and the procedural structure for, outside activity disclosure, the review of potential conflicts of interest, and the management of identified conflicts in research, sponsored projects, and technology transfer.
Research COI Committees
U-M Conflict of Interest Committees review the disclosures of outside activities from investigators listed on a U-M proposal application form (PAF) for sponsored research or a sponsored award (AWD) to determine whether an external activity could directly and significantly affect the design, conduct, or reporting of research. If a potential or actual conflict of interest related to the research, sponsored project, or technology transfer is found, the committee works with the individual (and the university regents, when applicable) to eliminate, minimize, or manage the conflict. There are two U-M Research COI Committees:
- OVPR COI reviews faculty and staff disclosures for the Ann Arbor (except Medical School and Health System), Flint, and Dearborn campuses
- MEDCOI reviews faculty and staff Medical School and Health System (U-M login required for link)
The goal of a Research COI Committee’s conflict of interest review is to ensure that the personal interests of an individual do not unduly influence his/her primary obligations to the science, sponsor, university, colleagues or students.
M-Inform is the university’s outside interest disclosure system.
(UMICH uniqname and password required)
See our Outside Interest Disclosure Process webpage for instructions, requirements, and more.
Discloser Roles & Responsibilities
Who is required to disclose?
For purposes of evaluating potential conflicts of interest in research and complying with the U-M COI in Research policy, any U-M faculty member, staff member, or student listed as an investigator on a U-M proposal approval form (PAF) for sponsored funding or a sponsosored award (AWD) must disclose their outside activities at least annually and within 30 days of any change to their outside activities thereafter.
Your school/college/organization may have a unit COI policy that further indicates who is required to disclose outside activities for other unit-level or University considerations in addition to research, such as conflicts of commitment (COC).
What if a potential COI is determined?
If a Research COI Committee determines that a potential or actual conflict of interest exists for one or more of your outside activities, you are expected to:
- Respond promptly to follow-up questions from the COI Committee
- Review and take action on a COI management plan
- Complete an annual review of the conflict situation/management plan
Who is considered an “investigator” for purposes of outside interest disclosure?
Any U-M faculty member, staff member, or student listed in one of the following investigator roles on a Proposal Approval Form (PAF) for sponsored funding or a sponsored award (AWD) is responsible for disclosing their outside activities in M-Inform and complying with the U-M COI in Research policy:
- U-M Principal Investigator
- U-M Sponsor Principal Investigator
- Participating Investigator with Specified Effort
- Participating Investigator without Specified Effort
- Other Non-Faculty Investigator
Outside activities, relationships, or interests (“outside activities”) are certain personal, professional, commercial, or financial endeavors you undertake with an entity/organization external to U-M in which you utilize the same professional expertise, service, or knowledge you provide to U-M, and which are not a part of a U-M administered research project.
Outside activities generally fall into five categories:
- Activities and relationships (paid or unpaid)
- International engagements
- Intellectual property (IP)
- Ownership interest (equity, stock, or stock options)
- Payments, loans, and reimbursements
Within each category there are specific activities, relationships, and interests you should and should not disclose to U-M. For details, see the Outside Activity Disclosure Guidance.
Questions?
- For questions about COI policy, outside interest disclosure, COI review and management processes, email [email protected].
- For questions about using M-Inform, the University’s Outside Interest & COI Management system, contact the ITS Service Center by phone, email, or online service request