Take home message: If it is possible that your outside interests could conflict or appear to conflict with the University’s interests, you have a potential (or perceived) conflict that should be disclosed to your supervisor for discussion or management.
- The Standard Practice Guide on Conflicts of Interest and Conflicts of Commitment(SPG 201.65-1) sets out the responsibilities of all faculty and staff relating to actual or potential conflicts, and the University’s framework for addressing them.
- The Provost and Executive Vice President for Academic Affairs maintains a collection of the relevant laws, policies, and training resources for < (COI/COC), including links to all approved U-M unit implementation policies for COI/COC.
- Every U-M unit has its own Unit Policy on Conflicts, through which the requirements of the SPG are implemented, in the way most appropriate to that unit’s activities and personnel.
- At UM-Dearborn, there are implementation policies for UM-Dearborn Faculty, and UM-Dearborn Staff. See also the UM-Dearborn COI/COC page maintained by the UM-Dearborn Office of the Provost, which includes disclosure forms, scenarios and checklists tailored to the UM-Dearborn community – including a useful checklist for managers about basic steps to take after an employee discloses a potential conflict.
- At UM-Flint, there are implementation policies for faculty UM-Flint Faculty and UM-Flint Staff. See also the UM-Flint COI/COC page maintained by UM-Flint Human Resources, which includes tutorials tailored to the UM-Flint community.
- If you are involved in research, read about conflicts of interest in sponsored research and technology transfer agreements. Additional regulatory requirements apply to those engaged in sponsored research: see this policy overview on the Office of Research and Sponsored Projects (ORSP) website.
- For those who conduct research funded by the National Institutes of Health (NIH) or other Public Health Service (PHS) agencies: new regulations are coming into effect on August 24th, 2012 that will significantly change the way you disclose your interests and manage your conflicts. Read more about this change at U-M Research: PHS Policy Change.
- Some conflict of interest situations require committee approval by a COI committee: For instance, the Office of the Vice President for Research (OVPR) Conflict of Interest Committee and the Medical School Conflict if Interest Board (MEDCOI) oversee conflicts connected to sponsored research projects or technology transfer, and the Clinical and Educational Conflict of Interest Committee reviews and approves certain conflicts in the U-M Health System (see the Clinical Conflicts page for more information). Individual Schools and Colleges (and other units) also have their own COI/COC committees: consult your local unit’s policy on conflicts or ask your local HR representative for more information.
- Some conflict of interest situations require Regental approval: Under Michigan law, U-M may not contract, directly or indirectly, with its employees without the approval of the Board of Regents. “Indirect contracting” can include being an employee of an outside company, owning large amounts of stock in an outside company, or being a member of the outside company’s board of directors. For more information, contact Procurement Services or, if the contract involves research or intellectual property licensing, the Office of the Vice President for Research.
- There are many helpful resources on the Provost’s website related to conflicts of interest and commitment, including a set of tools for supervisors or managers, a tutorial for faculty, and a tutorial for staff.
- In the busy and interconnected U-M community, conflicts of interest and commitment just happen – and they don’t mean you are a bad person! The important thing is that you know how to identify conflicts, disclose them to your supervisor, and work out how to manage them in a way that doesn’t compromise you or the University.
- Every U-M unit has its own conflict of interest and commitment management policy: make sure you are familiar with your unit’s specific policy and procedures.
- If you or your outside company are entering a contract with U-M, the contract may require approval by the Board of Regents. Check with Procurement Services or (for research contracts) the Office of the Vice President for Research before finalizing such a contract.
- Potential conflicts are just as critical as actual conflicts – identifying conflicts before they actually happen puts you and the University in a much better position to avoid and/or deal with them.
- Perception is as important as reality when it comes to conflict – the appearance of conflict can be very damaging to your reputation and the University’s reputation, even if you don’t believe there to be a conflict. Think about how any situation might look to outsiders when assessing your behavior. If it is possible that your outside interests could conflict or appear to conflict with the University’s interests, you have a potential (or perceived) conflict that should be disclosed to your supervisor for discussion or management.
For advice on specific conflicts, you should speak to your supervisor, dean, director, the principal investigator of research studies you may be involved in, the UMHS Compliance Office (for Health System employees) or the Medical School Office of Regulatory Affairs (for Medical School employees). You could also speak to your unit’s HR representative, who can give you guidance on your unit’s conflicts of interest and commitment policy and procedures.
For advice or questions about the new NIH/PHS conflict of interest regulations, contact the Medical School Office of Regulatory Affairs (for Medical School employees) or Office of the Vice President for Research.
For advice on policy implementation relating to conflicts, or for general guidance about managing conflicts of interest and commitment, contact the Provost’s Office – by emailing them or using one of the other contact options listed at the bottom of the Provost’s conflicts site. The Office of the General Counsel also maintains FAQs on Conflicts that may answer your questions.
For supervisors needing legal assistance relating to conflicts of interest or commitment, contact Ndu Ozor (email@example.com) in the Office of the General Counsel.
Established 3/4/11, last updated 3/7/17 – Contact us if you believe any information is incorrect or outdated