Disclosure Review
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inTERP disclosures are reviewed in stages based on your responses. If no outside financial interests are reported, the system auto-approves the disclosure with a NO COI disposition. The Disclosure Office later reviews it for any reporting errors.
Conflict of Commitment Review:
If your disclosure involves conflicts of commitment related outside activities, it will be initially reviewed by your Chair. If additional review is necessary, your Dean or the next level of administrator will conduct a further assessment. The COC Administrators will review the disclosure and determine the appropriate course of action. If necessary, the Office of Faculty Affairs will provide additional guidance on the matter.
Conflict of Interest Review:
If your disclosure involves conflicts of interest related outside activities, it may undergo the following levels of review.
Departmental Review:
Your disclosure will be initially reviewed by your Chair and then your Dean or the next level administrator.
Administrative Review:
The Disclosure Office conducts additional review, and in some cases, the Chair of the COI Committee determines the appropriate disposition. If the COI Chair cannot determine the appropriate disposition, the COI Committee will also perform a review of the disclosure.
Committee Review:
The UMD COI Committee reviews the disclosure and decides on actions like accepting, revising, or requiring a management plan, or requesting more information. They may also determine no action is needed or recommend a best practices memorandum. If a management plan is necessary, the committee advises the President, who has the final approval.
Compliance Review:
In many cases, UMD offices must verify current and complete COI disclosures before research or sponsored programs can begin. These offices may include the Office of Research Administration, Institutional Review Board, IACUC, and Export Control. Without an up-to-date disclosure or if additional information requested by the COI Office is not provided, study approvals, facility use licenses, gifts, and research fund releases may be delayed.
Organizational Conflict of Interest Review:
Certain federal contracts include clauses to address potential OCIs in recipient entities. Federal regulations on OCIs are outlined in the FAR Subpart 9.5 "Organizational Conflicts of Interest" clause. If you are funded by such a contract, your disclosure will be reviewed by the OCI Committee. Any identified OCIs related to a proposal or ongoing research must be managed by mitigating or eliminating the conflict. These management measures may be detailed in a Mitigation Plan that is shared with the sponsor.
Institutional Conflict of Interest Review:
If you are a University Official and have submitted a disclosure, the ICOI Committee will also perform a review and identify conflicts and independently manages their associated risks to scientific objectivity and proper treatment of human and animal subjects.
** Many people mistakenly believe that if they disclose a potential conflict, it automatically means there is a conflict present and that they won't be able to participate in the activity. However, this is not true. The COI Committee is here to assist in addressing potential, perceived, and actual conflicts in a constructive manner.
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The majority of disclosures are resolved within 2-3 weeks, BUT the COI process can take 6-8 weeks depending on how quickly the routing goes through.
Considerations that add time to the review process include:
- Administrative questions requiring additional information or revision and re-routing to chair/dean.
- Timing of disclosure submission. The COI Committee meets monthly (except August) to review disclosures.
- To be considered for an agenda, the disclosure routing and administrative questions need to be finalized by the 1st of the month.
We appreciate your patience, as this process takes time. If you have questions or an urgent disclosure, such as for setting up an award or finalizing a Facilities Use Application, please contact interp@umd.edu. We’ll do our best to prioritize your request.