The 2024 Annual Disclosure of Financial Interest was released in COI-Smart on Jan. 5.
Individuals who are required to complete this disclosure received an email notification from COI-Smart on Jan. 5. This email indicated it is from outside the organization, as it is sent from the COI-Smart database, but it is a legitimate email and request to complete the required disclosure.
The email includes a link to complete the online 2024 Annual Disclosure of Financial Interest Questionnaire by March 31. All faculty and other personnel are encouraged to complete the disclosure at their earliest convenience upon receipt of the open disclosure email.
The following personnel are required to complete the annual electronic disclosure:
- Faculty members, excluding volunteer faculty
- Non-faculty directors and administrators and above
- Advance practice personnel
- Managerial/professional staff
- Research personnel
- All employees who have been issued a purchasing card
- UNMC signature authorities under executive memoranda 13 and 14. (If anyone knows of someone who needs to be added who was not notified via COI-Smart, please let Sara Ward know.)
- Contracting personnel in sponsored programs administration, procurement and UNeMed. (If anyone knows of someone who needs to be added who was not notified via COI-Smart, please let Sara Ward know.)
- Anyone responsible for the design, conduct or reporting of research
- Anyone otherwise directed to complete the disclosure form
If an individual completed the 2023 Annual Disclosure of Financial Interest, the 2024 disclosure will auto-populate with the answers given in 2023. The respondent will navigate through each question and determine if the previous answers provided still are 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 (any activity/payment that was completed and payment received is greater than 12 months from date of disclosure) should be deleted. There is a red “X” on the tab in which that entity is listed. Deleting an entry can only be done before the disclosure is initially submitted for the first time of the reporting 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.
Conflict of Interest Management Plans are signed electronically via DocuSign, and the signed plan then is sent to the respondent with the conflict of interest, the study principal investigator (if not the respondent with the COI), department administrator, division chief/director if applicable, department chairperson or dean, the Institutional Review Board, sponsored programs or UNeHealth and business and finance for business conflicts of interest).
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). An Application to Engage in Outside Professional Activity must be on file for any activity in which a respondent has a significant financial interest, greater than $5,000. These forms cannot be backdated and can only be submitted for up to 12 months. If after one year a respondent still is providing services, a new form must be submitted for approval. Per UNMC policy, respondents shall complete an Application for Authorization to Engage in Outside Professional Activity Form prior to engaging in outside professional employment. Permission cannot be requested to engage in an activity that already has occurred.
Respondents are responsible for updating their disclosure with new activities throughout the year. The disclosure is available year-round and should be updated within 30 days of providing services and/or receiving payments for services provided.
With questions, please contact Sara Ward.