CoI FAQs

 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.

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.

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.

The 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.

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

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.

• Yes. The Ethics Law restricts secondary employment by officials and employees of the State. For purposes of the Ethics Law, the State position is primary employment, and all other employment is secondary employment. Section 5-502(b)(1) of the Ethics Law prohibits an official or employee from having secondary employment with an entity that does business with, is regulated by, or is under the authority of the State department or agency with which the official or employee is affiliated. Secondary employment includes compensated employment with an entity and non-compensated service involving a fiduciary relationship such as service on a board of directors. Secondary employment under the Ethics Law includes the following situations:
• Compensated employment with a for-profit or non-profit entity;
• Compensated employment with local government or a federal agency;
• Compensated employment with another State agency;
• Service as an elected official at the local level;
• Service on a State, federal, or local government board or commission with or without compensation; or
• Service on a for-profit or non-profit board or commission with or without compensation
• If you receive compensation for consulting or for other services provided to an entity, including another institution or a federal agency, that is doing business with UMB a conflict of interest exemption is required from the UMB President or a review from the State of Maryland Ethics Commission. Please disclose these relationships in the eDisclose financial disclosure application at cicero.umaryland.edu or contact UMB's Conflict of Interest Officer for further guidance.

• Yes. Under the State of Maryland Public Ethics law an official or employee may not be employed or have a financial interest in an entity that is doing business with UMB, unless a conflict of interest exemption is granted by the President of the University or a review is completed by the State of Maryland Ethics Commission. Secondary employment under the Ethics Law includes:
• Compensated employment with local government or a federal agency.

• If you receive compensation for consulting or for other services provided to an entity, including another institution or a federal agency, that is doing business with UMB a conflict of interest exemption is required from the UMB President or a review from the State of Maryland Ethics Commission.

• Under UMB's policy on Professional Consulting and Other External Professional Activities, prior approval is required. Please disclose these relationships in the eDisclose financial disclosure application at cicero.umaryland.edu or contact UMB's Conflict of Interest Officer for further guidance.

• A financial interest in an entity that's doing business with UMB triggers a conflict of interest review and often requires a conflict of interest exemption from the UMB President. Many startup companies are based on UMB owned technologies that require a technology licensing agreement between UMB and the startup company, and that business agreement along with an employee's financial interest in the startup company requires a conflict of interest review.
• If you have a financial interest in a startup company that plans on doing business with UMB, you must request a conflict of interest review by submitting a conflict of interest exemption request in the eDisclose financial disclosure application at cicero.umaryland.edu, before the University may enter into a technology licensing agreement.
• Subawards from UMB to startup companies also require additional reviews. A subaward approval must be in place before a subaward is granted to a startup company. This document is reviewed by a Department Chair, the Vice President and Chief Research Officer and the Provost. Please contact UMB's Conflict of Interest Officer for further guidance.