— Academic Affairs — Compliance — Conflict of Interest

Conflict of Interest

UNMC policy requires faculty, research personnel and other personnel to submit a conflict of interest disclosure upon employment and at least once annually thereafter.

We use COI-SMART to complete, track and manage conflict of interest disclosures and applications to engage in outside professional activity, otherwise known as outside employment. (Note: You will need to use your NetID and password to log in).

If you need help accessing or navigating COI-Smart, read our Quick Start Guide.

Access COI-SMART

Any outside professional activity requires approval prior to participating in the activities. Approval takes time, so be sure to plan accordingly. If you have any questions along the way, please email Sarah Gloden Carlson, Chief Compliance Officer.

Process for Outside Employment Approval

Step 1: Get Departmental Approval

Step 2: Submit Application for Authorization

Step 3: Obtain Approval Signatures

If an outside employment opportunity is offered, you need to work with your department administration to determine what type of outside employment is being offered and whether that type of employment is prohibited by UNMC policy.

Important: Speaker's bureau participation is prohibited and being paid/reimbursed by an outside vendor to attend a conference where one is not presenting or providing conference services is also prohibited.

Be sure to follow these guidelines:

Speaker's bureau is defined as any direct marking activities on behalf of health care vendors.
A faculty member may not deliver content prepared by industry endorsing a product or service provided by that sponsor that is not his/her own original content.
A faculty member may provide unbranded disease awareness presentations sponsored by health care vendors with disclosure to and approval by Department Chairs. It must be the faculty member's own/original content.

Before engaging in the activity, you must submit an application using COI Smart.

A faculty member can complete this form for up to a 12-month period (for example, Jan. 1, 2021 – Dec. 31, 2021). A new application can be submitted for further paid activities prior to the end of the 12 months to ensure ongoing approval for participation. (Retro dated forms are not accepted.)

Be sure to read our instructions on how to access COI-SMART to complete the online Outside Activity Application.

After you submit the application, the Conflict of Interest Office will send a copy of the form via DocuSign to review and sign. The form will be electronically routed for the following signatures:

Respondent signature
Section Chief Signature (if applicable)
Chairperson/Director/Supervisor Signature
Dean/Dean Business Office Signature
Chief Compliance Officer Signature
Vice Chancellor Business and Finance
Chancellor Signature

After all individuals have approved the application, a final copy will be sent to those who signed and the department administrator for departmental records.

Once you have submitted an Application for Authorization to Engage in Outside Professional Activity, you need to ensure your Annual Disclosure of Financial Interest accurately reflects your requested activity via COI Smart.

Open Payments Reporting

Faculty payments from industry are reported through the CMS Open Payments Database, a national disclosure program that promotes a more transparent and accountable health care system.

Activity reported on this site is not a bad thing. What is a bad thing is if activity is reported on this site and the institution does not have record of the activity via the disclosure process.

Open Payments also lets covered health care providers review their information and dispute inaccuracies (if any).

Learn about Open Payments

UNMC Policies

University of Nebraska Policies & Laws

Federal Regulations & Guidance

Sarah Gloden Carlson, JD

Chief Compliance Officer

Send Email

Phone: 402-559-9576

Conflict of Interest

Process for Outside Employment Approval

Open Payments Reporting

Conflict of Interest Policies & Procedures

Sarah Gloden Carlson, JD