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COI Initial Review Process

There are three (3) COI Review processes:  

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

The disclosures that go through the initial review process conducted by a COI Office are those that:

  • Reference a PHS project, and/or 
  • Indicate an outside interest related to research, and/or
  • Are by an individual with an existing COI management plan 

As a U-M employee, you participate in this process by:

M-Inform is the university's outside interest disclosure and COI management system.

The conflict of interest (COI) review is an essential part of U-M's research compliance processes.  If a conflict of interest is determined, it must be effectively managed before U-M can accept internal awards, sponsored awards, or finalize agreements, such as research subcontracts or technology transfers agreements.

Initial Review

The U-M COI offices (COI-UMOR, MEDCOI) identify potential conflicts of interest in research by reviewing:

  • Outside interest disclosures in M-Inform
  • Research activity records in eResearch, as applicable, including:
    • Proposal Approval Forms (PAFs)
    • Subcontract Agreements (SUBKs)
    • Human Subject Research Study applications (HUMs)
    • Unfunded Agreements (UFAs), such as Material Transfer Agreements (MTAs)
  • Technology transfer agreements from the U-M Office of Technology Transfer (if applicable)
  • Company profiles for U-M start-ups in M-Inform (if applicable)

Review Criteria

In general, the COI offices review the situation created by the combination of the external entity, your activity with that external entity, and your sponsored research conducted at or through the University of Michigan to identify if a potential conflict of interest exists.

Specifically, the COI offices evaluate your disclosure of:

  • Paid or unpaid activities for, and relationships with, an external entity that utilize same skills and knowledge associated with your U-M job responsibilities. (This does not apply to professional society memberships.)
  • Ownership in a company or business, including equity, stock, or stock options
  • Intellectual property rights or interests, including license and option agreements made through the Office of Technology Transfer for technology, etc. developed at U-M, and non-UM patents, copyrights, and royalties
  • Compensation, loans, or items of value received from external entities for activity related to you U-M job responsibilities (not including student loans)
  • Travel expenses that are reimbursed to you or paid directly by an external entity, as required by PHS regulations and/or your unit's COI policy.

If more information is needed:

If a COI office requires additional information in order to identify if a potential conflict of interest exists, you will receive an email with a link to the online Research Certification (RC) in M-Inform.  Using the RC, you answer a series of questions to provide detail to the COI office via the M-Inform system (see References & Resources below for downloadable instructions).

References and Resources

Disclosers

Questions?

For questions regarding Research Certifications or other U-M conflict of interest review processes, email COI.Support@umich.edu.