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As a researcher at the University of Michigan, you are expected to report (i.e., disclose) any outside activity, relationship, or interest ("outside activity") with an external entity (e.g, company, organization, etc.) to U-M for a conflict of interest (COI) review by a COI Office. Your outside activity disclosure ensures that you and U-M are compliant with the federal and state regulations designed to safeguard objectivity in research.
The University’s annual disclosure process begins July 1 with each new fiscal year. Complete the annual process in M-Inform beginning July 1, but update your disclosures within 30 days of any changes thereafter.
M-Inform is the university’s online outside interest disclosure system. M-Inform is an eResearch system supported by ITS. As an employee, you use this system to complete and submit the disclosure form(s) on, at least, an annual basis.
Disclosing may include reporting that you do not have outside activities or reporting outside activities with more than one external entity.
Each disclosure is reviewed by your unit and, if applicable, by a U-M Conflict of Interest review committee (UMORCOI or MEDCOI) to ensure compliance with federal, state, and university policies. If a conflict of interest is identified upon review, the COI committee works with you to manage the conflict to mitigate the impact on your research.
COI Attestation Process in the eResearch Applications
As a Principal Investigator (PI) or a study team member, completing a conflict of interest statement is a required part of the eResearch processes to:
- Submit applications for sponsored funding proposals via the proposal approval form (PAF)
- Accept a study team role on, or submit IRB applications for, human subjects studies (HUMs)
- Approve draft subcontract (SUBK) agreements
- Submit unfunded agreements (e.g., material transfers) related to proposals or awarded projects
This attestation is not equivalent to completing an outside interest disclosure in M-Inform. In eResearch applications you will see text reminding you to disclose any outside interests related to the research activity.
The eResearch IRB application (HUM) is integrated with M-Inform in that the U-M PI or study team member sees their disclosure status and a link to M-Inform as part of the COI statement. Per U-M and HRPP policies, you are required to disclose in M-Inform if you have an outside interest related to the HUM and you do not have a current disclosure in M-Inform. If you have a current disclosure in M-Inform, you are expected to update that disclosure when an outside interest applies to a new HUM; or amend an active HUM (and your current disclosure) when a new related outside interest arises or a change occurs to an existing related outside interest. See the Discloser procedures for instructions.
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.
References and Resources
Who do I contact for help?
Check with your unit's administration about unit-specific policies, requirements for outside interest disclosure, and M-Inform role assignments (e.g., unit reviewer).
If you need help using the M-Inform system, contact the ITS Service Center:
If you have questions about COI policy, outside interest disclosure requirements and review processes (including reviewer assignments), and COI management processes, email COI.Support@umich.edu.