Non-U-M Investigator Disclosure Process

Individuals not affiliated with (i.e., not employed by) U-M may be required to disclose outside interests related to the proposed research when listed as an investigator on:

• A subcontract from U-M to an external organization for a project that is funded by a sponsor following the PHS financial conflict of interest (FCOI) regulations
• An IRB application for a U-M human subjects study

If the individual's organization or institution (i.e., employer) does not have their own process to report and manage conflicts of interest, the non-UM investigator can disclose to the University of Michigan using the Non-U-M-Affiliate Financial Interests Disclosure Form.

Roles & Responsibilities

University of Michigan

• For a subcontract, the U-M Office of Contract Administration will send the disclosure form to the non-U-M affiliate(s) for completion.  
• For IRB applications, the U-M study team will send the disclosure form to the non-U-M investigator for completion. Returned forms are uploaded into eResearch for appropriate review by a U-M COI Office.

Non-U-M Affiliate

• Complete the disclosure form, as applicable to the proposed research
• Follow the instructions provided by the U-M department that sent you the form to submit the completed form to the university.