The 2022 Annual Disclosure of Financial Interest will be released in COI-Smart on Jan. 17.
Individuals who are required to complete this disclosure will receive an email notification from COI-Smart on that date. The email will include a link to complete the online 2022 Annual Disclosure of Financial Interest Questionnaire by March 31, along with the Application for Authorization to Engage in Outside Professional Activity forms.
Please let your faculty and other personnel know to expect these emails in the near future and encourage them to complete the disclosure as soon as possible (see UNMC Conflict of Interest Policy 8010).
The following personnel are required to complete the annual electronic disclosure:
- Faculty members (excluding volunteer faculty)
- Non-faculty directors and administrators and above
- Managerial/professional staff
- Research personnel
- All employees who have been issued a purchasing card
- UNMC signature authorities under executive memoranda 13 and 14
- If you know of someone who needs to be added that was not notified via COI-Smart, please contact Sara Ward.
- Contracting personnel in sponsored programs administration, procurement and UNeMed
- If you know of someone who needs to be added that was not notified via COI-Smart, contact Sara Ward.
- Anyone responsible for the design, conduct or reporting of research
- Anyone otherwise directed to complete the disclosure form
If the individual completed the 2021 Annual Disclosure of Financial Interest, the 2022 disclosure will auto-populate with the answers given in 2021. The respondent will navigate through each question and determine if the previous answers provided are still appropriate. The respondent can then "Use this answer," edit the answer, delete the answer and/or add additional information where applicable.
It is important that each question is reviewed, and any disclosure that is no longer relevant (activity and payment was completed and received greater than 12 months from date of disclosure) should be deleted. Deleting an entry can only be done before the disclosure is submitted. Please remember respondents are responsible for updating their disclosure with new activities throughout the year.
The completed questionnaires will be reviewed by the UNMC Compliance Department. Potential conflicts of interest will be reviewed by the UNMC conflict of interest committee, Institutional Review Board (for human subject research), business and finance (when applicable) and Nebraska Medicine (if applicable). Management plans will be developed if it is decided there is a conflict to be managed.
The signed COI management plans are sent to department administration to distribute to the respondent, department administrator, division chief/director (if applicable) and the department chairperson or dean. The Institutional Review Board, sponsored programs or UNeHealth and business and finance (business conflicts of interest) also receive a copy of the signed management plan.
The Application to Engage in Outside Professional Activity also is available electronically in the COI-Smart system for respondents to complete for any outside professional activity (see UNMC Outside Employment Policy No. 1049).
With questions, please contact Sara Ward.