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Nepotism


Personal and familial relationships can create real or perceived conflicts of interest in research, teaching, hiring, supervision, and related activities. To protect research objectivity and meet legal and sponsor obligations, UMass Dartmouth requires disclosure of relationships that could create the appearance of favoritism or bias.

What to disclose:

Disclose any spouse, domestic partner, immediate family member, dependent, or close personal associate who meets any of the following:

  1. Is an investigator, key personnel, paid staff, or unpaid contributor on thesame project;
  2. Is supervised, evaluated, hired, or otherwise directly affected by your research-related employment or academic decisions; or
  3. Has any role that could create the appearance of bias in research, teaching, financial, or administrative decisions.

Disclose annually and update within 30 days of any change (new appointments, hires, role changes, etc.). Ensure to disclose paid and unpaid roles, visiting or affiliate appointments, and anticipated relationships likely to occur within the next 12 months.

Why we require this:

  • Massachusetts law (M.G.L. c. 268A) restricts state employees from participating in matters affecting immediate family members and forbids actions that create the appearance of favoritism.
  • Federal regulations and sponsor rules require institutions to protect research objectivity and to ensure that personnel costs charged to awards are reasonable, allocable, and necessary.
  • Disclosure allows the University to manage potential conflicts early to avoid audit findings, disallowed costs, fines, corrective actions, or other enforcement risk.

 

Disclosure Process:

  1. Submission:Use the Kuali Conflict of Interest Module to disclose. Include the related person’s name, relationship, project/award or unit, sponsor (if applicable), role, whether they are paid by the same award, and whether you supervise/evaluate them.
  2. Review:The Office of Institutional Ethics & Compliance (in coordination with Research Compliance and Sponsored Programs, as appropriate) reviews disclosures to determine if a management plan is needed.
  3. Management:If required, the Office issues a written management plan and documents actions taken. If a disclosure affects federally funded research and meets sponsor reporting criteria, the University will file required notifications and, when necessary, perform a retrospective review. Disclosures and management plans are retained consistent with policy and made available for internal or sponsor review as required. 

 

Suggested Management Measures?

  • Reassign supervisory responsibilities so the related investigator is not evaluated or supervised by the relative.
  • Appoint independent data analysis or oversight (e.g., Data Safety Monitoring Board, external statistician).
  • Require separate signatory authority for expenditures and time charges.
  • Limit the related person’s role to non-decision-making activities (e.g., technician without hiring authority).
  • Require enhanced documentation of time-and-effort and independent review to protect against disallowed costs.
  • When necessary, notify sponsor and implement a documented management plan; perform retrospective review if the conflict is identified after project start.

FAQ:

Q: Do I need to disclose unpaid collaborators or visiting scholars?
A: Yes. Unpaid roles, visiting appointments, and affiliate positions can create the same appearance of bias and should be disclosed.

Q: What if my spouse/partner is listed on a budget as paid personnel?
A: Disclose immediately. Paid personnel on the same award can create allowability and audit issues; the University may need to document additional oversight or notify the sponsor.

Q: Will my disclosure be shared outside the University?
A: Disclosures are reviewed by the Office of Institutional Ethics & Compliance and may be shared with Research Compliance, Sponsored Programs, or a sponsor if required by law or policy. The Office treats disclosures confidentially to the extent permitted by law.

Q: What happens if I fail to disclose?
A: Failure to disclose can result in administrative action and may expose the University and individuals to audit findings, sponsor repayment, state fines, or other enforcement (including potential civil exposure under the False Claims Act where nondisclosure amounts to a material misrepresentation).

Need help?

Contact the Office of Institutional Ethics & Compliance: disclosure.info@umassd.edu. If you’re unsure whether a relationship requires disclosure, please ask for confidential guidance and potential management options.