Disclosing the required information at the earliest possible time affords the best protection of an investigator's interests. Investigators are encouraged to disclose any situation that could conceivably be viewed as a conflict of interest or a reportable financial interest. When in doubt, it is safer to disclose. The UNM Conflicts of Interest Committee will assess whether an actual or potential conflict exists, and will work with the investigator to determine how it should be resolved or managed. Please allow 4-6 weeks to complete the COI review process.
Disclosure requirements apply for all of the following types of research:
Disclosure is applicable to all investigators, including faculty, staff and students. Investigators are defined in the COI policy as anyone responsible for a task that could have a significant effect on the design, conduct or reporting of the research. It is the responsibility of the Principal Investigator (PI) to identify the investigators and inform them of the policy requirements. Non-UNM investigators employed by sub-award institutions must follow their institutions COI policy, or if none exists they may use UNM's process. Non-UNM investigators (individual consultants) must file a non-UNM disclosure form. Each investigator must then disclose relevant financial interests and provide this information to the appropriate UNM institutional unit who process the proposals or protocols, and at least annually thereafter or sooner if a new conflict arises.
UNM institutional units requiring COI disclosure submissions:
Significant financial interests include those of the investigator, his or her spouse or domestic partner and dependent children. Generally, the following financial interest must be disclosed:
Interests are 'related to the research' if an investigator has a relationship with an entity outside of UNM that has either an interest in the subject matter of an investigator's research or whose activities overlap with an investigator's area of expertise. Remember family relationships also count. Conflicts of interest frequently involve perceptions, and are judged by others, not by those directly involved. When evaluating the disclosure of a potential conflict of interest, it is important to consider how it may be perceived by others. UNM favors more rather than less disclosure. Disclosure does not automatically mean a conflict this is what the Committee will decide.
Examples of situations requiring disclosure:
The UNM COI disclosure form is a confidential disclosure of each investigator's interests. A COI disclosure form should be submitted with each proposal or protocol, and annually thereafter. If the investigator's situation changes after submission, or after the award is received a new disclosure form must be filed within 30 days. When in doubt, it is safer to disclose.
To assist the COI Committee and to speed up the review process, it is essential that the investigator provides sufficient information for the COI Committee to make a decision. If the investigator answers 'YES' to any of the questions on the disclosure form, then he or she must provide a description of the financial or fiduciary interest or affiliation, and how it relates to the current proposal or protocol as well as a description of any measures taken to manage any possible conflict or give suggestions as to how the conflict may be mitigated. Please allow 4-6 weeks to complete the COI review process.
Download the Conflict of Interest Disclosure Forms and Information
For each proposal or protocol, the cover sheet is prepared by the PI and each investigator prepares the appropriate disclosure form.
Conflict of Interest Definition and Examples
Cover Sheet and Main Campus UNM Conflict of Interest Disclosure Form
Non-UNM Conflict of Interest Disclosure Form
Non-UNM Conflict of Interest Disclosure Form (Spanish)
Cover Sheet and HSC UNM Conflict of Interest Disclosure Form
Under UNM's COI policy and applicable federal regulations, investigators have an ongoing duty throughout the period of their research projects to update conflict of interest disclosures, either annually or as new financial interests arise that would reasonably appear to affect their research projects. A conflict of interest disclosure expires one year after submission. If an updated disclosure is submitted prior to the expiration date due to a significant change in financial status, then the one year period would commence upon submission of the new disclosure. Investigators are responsible for tracking the expiration dates of their disclosures and for submitting updated disclosures. COI disclosures are also required at the time of a grant renewal application, and at the time of any protocol renewal or amendment. The forms must be submitted to the various UNM units (HRRC, IRB, IACUC, HSC Pre-Award and ORS Contract and Grant Administration) no later than 30 days prior to the expiration date.