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COI Annual Review Process

There are three (3) COI Review processes:

  • Initial Review
  • Determination & Response to Management
  • Annual Review

Situations where the committee determined that management is required for an existing conflict are reviewed annually.

As a U-M employee, you participate in the Annual Review process either as the conflicted individual or as someone with an oversight role (e.g., ombudsperson). 

Annual Review of a Conflict Situation

All active COI Management Plans are reviewed on a regular basis (at least annually) to verify that the:

  • Conflict situation still exists
  • Individuals and their roles with the research or external entity are confirmed
  • Appropriate individuals (e.g., ombudspersons) have a role in the management of the conflict
  • Disclosure of the conflict situation has occurred (e.g., to students, in publications, etc.)

Using M-Inform

At this time, the conflicted individual and other individuals required to review a COI Management Plan receive an email with a link to the Annual Review (AR) in M-Inform.  Using the AR, you will answer a series of questions to update the detail related to the management plan.  Submission of your answers in M-Inform allows the COI Office to conduct the review, which may include revisions of the plan.  Revisions require accepting the updated plan in M-Inform.  (See the Responding to a COI Management Plan section for more information.)

Potential Annual Review Outcomes

Upon completion of the annual review, the COI Management Plan may have one of the following states:

  • Under Management: The conflict situation continues to be managed via annual review.
  • Management Ended – Awaiting Publication: The research project has ended, but the disclosure of the conflict of interest is required in subsequent publications or presentations of the research results.
  • Management Ended: The research project has ended.  Subsequent annual review for the conflict situation is not required.
  • Conflict Eliminated:  The relationship with the external entity has ended.  Subsequent annual review for the conflict situation is not required.

References and Resources

Disclosers

Ombuds, Monitors, Other Approvers

Questions?

For questions regarding the Annaul Review process, email COI.Support@umich.edu.