Kuali COI module goes LIVE and Important Reminder: Conflict of Interest Policy and Procedures and Mandatory Training

TO: Faculty & Staff
FROM: Amitabh Varshney
Interim Vice President for Research
SUBJECT: Kuali COI module goes LIVE and Important Reminder:
Conflict of Interest Policy and Procedures and Mandatory Training


We are excited to let the research community know that the Kuali Conflict of Interest (KCOI) module will be online and ready to use as of November 8th.  The new electronic system eliminates paper conflict of interest (COI) disclosures and will also be the system of record, in place of IRBnet, for FCOI (Financial Conflicts of Interest) disclosures.

Importantly, KCOI disclosures are living documents.  Information provided in a previous disclosure will automatically populate the new disclosure; the researcher is responsible for revising and updating the information.  KCOI allows for the assignment of delegates to aid researchers in uploading information to their disclosure, but the researcher cannot delegate the authority to certify the disclosure.  The researcher, and only the researcher, MUST verify the disclosure, review the updates, certify, and submit.  The Division of Research COI webpage includes more information, instructions, training resources, and additional details regarding the KCOI process.

This notification also serves as a reminder that all University employees must comply with the University of Maryland's Conflict of Interest (COI) and Conflict of Commitment (COC) Policy and Procedures. Non-compliance with the University’s Conflict of Interest and Conflict of Commitment Policy or these procedures may be a violation of State Ethics Law and may result in disciplinary action and/or other sanctions in accordance with University policies, State Ethics Law, or other applicable State or federal laws and regulations, including the suspension or termination of a sponsored project.  Non-compliance could also result in restrictions on employees with respect to future proposal submissions.  Failure to properly disclose outside professional activities when required on sponsored research proposals funded by the U.S. government could also result in a violation of U.S. Federal Law.

Please note that all disclosures must be initiated and submitted by the Principal Investigator (PI), Co-Investigators, and any UMD senior/key personnel with a COI or FCOI to disclose and MUST be reviewed and signed by the PI/Co-I/senior/key personnel, the Unit Head, and the Dean.  These roles CANNOT be delegated and must be signed by the Unit Head and Dean.  All identified conflicts of interest must be satisfactorily managed, reduced, or eliminated either prior to the University’s expenditure of any funds under an award for any sponsored project or in the case of DOE ARPA-E, before the acceptance of the award.

For more information about roles and responsibilities associated with the proposal process, please visit the Office of Research Administration Roles and Responsibilities webpage.

Thank you for your attention to this important policy.



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