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The following FAQs define key terms found in the university's outside interest disclosure system, M-Inform, and in U-M's conflict of interest policies and procedures. Knowing the definition or details about these terms may help you determine what you are required to discose as an outside activity, relationship, or interest to U-M.
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.
In general, an "outside organization" (or an "outside entity") is any entity external to U-M, such as:
- A company (for proft whether publicly traded or not, non-profit);
- An institution, program, or society (academic, professional, or commercial, whether US-based or international)
- U.S. government (federal, state, or local); or
- A foreign institution, government, or company.
U-M applies exceptions for the disclosure of outside activities to some external entities. See the Outside Activity Disclosure Guidance for details.
A “non-US entity” is considered any corporation, society, or other entity/group that is not incorporated or legally organized to do business in the U.S. This includes any foreign government. This does not include U.S. incorporated subsidiaries of non-US-based foreign entities.
Institutional responsibilities are your professional duties/work on behalf of the University of Michigan. These may include, but are not limited to:
- Conduct of sponsored projects, including administration
- Professional practice
- Service on institutional committees
An outside activity is considered "related" to your institutional role/responsibilities when:
- The outside activity relies on or utilizes your area of expertise, scholarship, employment;
- The outside activity has the potential to influence your U-M duties/responsibilities (research, teaching, clinical, or public service); or
- The external entity associated with your outside activity does business with U-M (e.g., sponsors research, vendor).
An equity interest includes any stock, stock option, or other ownership interest in an outside organization/entity.
You are not required to disclosed to U-M equity from mutual funds, retirement accounts, or similar managed investments where you do not directly control the investment decisions within the portfolios.
Payments for the sale or use of intellectual property (IP) paid to the owner of the IP and/or its inventor by an external entity. U-M does not require you to disclose book royalties, but does require you to disclose as an outside interest any royalties for your IP that is licensed/optioned through the Univeristy of Michigan and/or other entity.
Disclosable travel expenses include hotel, air, and ground transportation, and other travel costs paid for by an outside organization/entity.
All travel expenses paid or reimbursed by a foreign entity, including academic and healthcare institutions, governments, companies or non-profit organizations must be disclosed at any dollar amount.
You are responsible for disclosing travel expenses paid or reimbursed by a domestic (U.S.) entity, domestic professional society, or domestic non-profit organization if the aggregate expenses exceed $5,000 in any rolling 12-month period.
Professional effort, as it relates to outside interest disclosure, is the expenditure of time (measured in days) to perform or support an outside activity.
For example, if you spend 8 hours in a given day on a professional activity (e.g., research) and 4 hours of that day is spent on behalf of your outside activity, you would calculate 0.5 days of professional effort spent on that outside activity. If you spent 0.5 days six times per year on that outside activity, you would enter 3 days of professional effort when disclosing the outside activity in M-Inform.
If the outside activity involves no spent time (e.g., royalties, stock ownership) or if you disclose an outside activity of your spouse or dependent, enter 0 days for professional effort.
A Conflict of Commitment (COC) exists when your effort (i.e., time and intellectual energy) spent on an outside interest, activity, or relationship could interfere or compete with your ability or willingness to perform the full range of responsibilities associated with your position at the University of Michigan (i.e., institutional responsibilities); or could interfere or compete with the university's missions (teaching, research, service, etc.).
The start/initial date of an outside activity occurs at the point that a written or verbal agreement is established with the outside entity, or you begin work/activities with the outside entity.
Per U-M SPG 201.65-1, the U-M "COI in Research" policy, and the Public Health Service (PHS) financial conflict of interest regulations, a "family member" is defined as a spouse, domestic partner, and/or dependent children.
If a family member has an outside activity with an external entity that is doing business with your U-M department, you should disclose this activity in M-Inform if you are in a position to direct business to that entity.
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
A “non-US person” is an individual who is not a U.S. citizen, permanent U.S. resident, or protected person.
- U.S. permanent residents are also commonly referred to as green card holders.
- Protected persons include individuals who have been granted formal asylum status or other protected immigration status.
An individual’s visa status (e.g., student F1 visa, visiting scholar J1 visa, H1B visa) does not override their citizenship.
An external entity conducts business with U-M when that entity and U-M enter into a transaction, including, but not limited to:
- Sponsoring/funding research, testing, or training,
- Subcontractor on a research project,
- Vendor/supplier for procurement (e.g., purchasing) purposes,
- Giving a gift to the University, or
- Providing goods or services (e.g., equipment, drugs, devices) for research purposes or other U-M business purposes.
The "aggregated value" of an outside activity is the dollar value that you and/or your family member have received from an external entity in the past 12 months including the current value of equity you (and/or your family member) hold in the entity, even if you did not receive a payout of said equity, and excluding travel.
M-Inform Disclosure Hints
- If you are disclosing equity held in a non-publicly traded entity but you don't know the value of the equity, select "No" to the "Is the dollar value of the equity known" question in M-Inform. This "No" answer indicates that the Aggregated Value amount excludes the unknown equity value.
- If you are disclosing an outside activity for a family member only and are not privy to the dollar value received, select "$0 (None)" from the list in the Aggregated Value field and provide an explanation in the "other relevant information" field in M-Inform.