About

Financial conflict of interest

A Financial Conflict of Interest (FCOI) is a situation in which an employee’s private financial interest might interfere or appear to interfere with his or her professional obligations to UMass Dartmouth or the conduct of the research. FCOIs in research have the potential to increase bias in research or create the appearance that research has been biased, regardless of whether or not that is the case. Furthermore, an FCOI can compromise, or be perceived as compromising, important academic values, research integrity, or the university mission.

Conflict of commitment

A Conflict of Commitment (COC) is a situation in which an employee engages in an outside professional activity, paid or unpaid, that involves a commitment of time that may interfere, or appear to interfere, with the fulfillment of the employee's obligations to the University, even if the outside activity is valuable to the University or contributes to the employee's professional development and competence.

Required outside activities disclosure

UMass recognizes the value outside activities can be to faculty and the University. Per the Massachusetts Law (Chapter 268A: Conduct of Public Officials and Employees), UMass faculty are considered special state employees as they are permitted to engage in limited activities outside of the University during regular working hours; provided such activities do not interfere with their primary obligations.
UMass Dartmouth requires an annual disclosure from all faculty members regarding Outside Activities or confirmation of lack thereof. Per the UMass Policy on Consulting and Outside Activities (Trustee Policy T96-047), faculty members are expected to devote their primary professional loyalty to the University and direct their time and energy to the University. UMass considers outside activities to be non-academic activities, within your area of expertise, that you take part in association with individuals or entities outside the University; including outside activities while on sabbatical.

Disclosure reporting

All UMass Dartmouth faculty and staff are expected to comply with the university’s COI policies by disclosing any significant financial interests prior to submission of grant/contract proposals to the Office of Research Administration and disclosing significant financial interests on an ongoing basis as required by sponsors. All University employees are subject to the requirements of State laws regarding Conflict of Interest. As Commonwealth of Massachusetts employees, the disclosure of outside activities is required by the Massachusetts State Ethics Board.
The Director of Institutional Ethics & Compliance provides oversight and support for the process of disclosure of any potential, real, or perceived conflict of interest, review of conflicts, and management of identified conflicts. The UMass Dartmouth Campus Conflicts of Interest Committee meets, as needed, and is responsible for the initial review of potential conflicts of interest. The UMass System Conflicts Committee then reviews the conflict and provides final guidance as necessary to the employee, typically as a conflict management plan. UMass Dartmouth has two representatives on the UMass system Conflicts Committee - a faculty representative and the Vice Chancellor for Research and Innovation (or designee).

Government, foundation, industry funded researchers

The corresponding form is required to be filed for every proposal to private foundations, industry, and any government entity that has not adopted PHS/NIH or NSF policies. Please submit it with the Proposal Routing Form (PRF). It is required for all Investigators and any other person who is responsible for the design, conduct, or reporting of the research. If an Investigator has a reportable financial interest, it must be disclosed to ORA when the Investigator submits the relevant grant proposal and whenever a reportable financial interest arises during the period of an award

Public Health Service Agency funded Researchers

The U.S. Public Health Service (PHS) amended its Financial Conflict of Interest (FCOI) Regulations effective August 24, 2012. These regulations have unique reporting and conflict management requirements and require initial disclosure of all financial interests related to the institutional responsibilities of the investigator to the Office of Sponsored Programs Administration. The PHS Summary Disclosure Form is required for proposals to: the Office of Global Affairs (OG); Office of the Assistant Secretary for Health (OASH); Office of the Assistant Secretary for Preparedness and Response (ASPR); Agency for Health Care Research & Quality (AHRQ); Agency for Toxic Substances and Disease Registry (ATSDR); Centers for Disease Control and Prevention (CDC); Food and Drug Administration (FDA); Health Resources and Services Administration (HRSA); Indian Health Service (IHS); National Institutes of Health (NIH); Substance Abuse and Mental Health Services Administration (SAMHSA); Lupus Research Alliance (LRA); American Asthma Foundation; American Cancer Society (ACS); American Heart Association (AHA); American Lung Association (ALA); Arthritis Foundation (AF); CurePSP; Juvenile Diabetes Research Foundation (JDRF); Lupus Foundation of America (LFA); Patient-Centered Outcomes Research Institute (PCORI); Susan G. Komen for the Cure

PHS regulations require investigators to undergo COI training every four years. Training is provided through CitiProgram. Select "complete conflict of interest training." There are two required modules: (1) Financial Conflicts of Interest: Overview, Investigator Responsibilities, and COI Rules (COI-Basic) (ID: 15070) and (2) Institutional Responsibilities as They Affect Investigators (COI-Basic) (ID: 15072).

National Science Foundation funded researchers

Faculty investigators who are supported by external funding from the National Science Foundation (NSF) and other federal agencies adopting the NSF requirement, must submit an NSF summary disclosure form with each proposal. The summary disclosure form must be updated whenever an investigator obtains new reportable significant financial interests.

Foreign Influence and Engagement

Increased concern has been expressed through both legislative actions and agency regulations about protecting national security and U.S. economic interests when taxpayer dollars fund the University’s work. It is important that we be responsible stewards of these funds and ensure that we are mindful of protecting intellectual property, as required by the terms of our funding. A number of Federal research-sponsoring agencies have requirements for disclosing foreign engagements due, in part, to concerns about the relationship between foreign engagements and research integrity.

Foreign engagements include, but are not limited to, the following:

Researcher employment with foreign entities or governments;
Other positions, appointments, or affiliations with foreign entities or governments. These may include, but are not limited to, titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary);
Consulting arrangements with foreign entities or governments;
Receipt of other research support, contractual or otherwise, directly or indirectly, from foreign entities or governments. Examples of such support may include, but are not limited to, gifts, financial support for laboratory personnel, provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.), and in-kind contributions, e.g., office/laboratory space, equipment, supplies, or employees or students supported by an outside source;
Researcher participation in foreign government-sponsored talent recruitment programs; and
Current or pending participation in or applications to programs sponsored by foreign governments, instrumentalities, or entities.

Principal Investigators, Project Directors/Managers, and Key Personnel on federally funded projects should pay particular attention to the referenced notices issued by those agencies on July 10, 2019 (NIH) [NIH Policies on Other Support and on Policies related to Financial Conflicts of Interest and Foreign Components] and July 11, 2019 (NSF) [NSF 19-200, Research Protection], and February 14th, 2024 (OSTP) [Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs] which provide clarification about required disclosures and participation in foreign government talent recruitment programs. The University strongly recommends researchers seeking sponsorship from other federal agencies also disclose such information.