UMass Boston

In accordance with federal regulations, UMass Boston has a responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by a financial interest of an investigator. Federal regulations require institutions to have policies and procedures in place to ensure that investigators disclose any significant financial interest that could affect the design, conduct, or reporting of funded research. 

To ensure objectivity and stewardship of public funds, members of the University community are expected to:

• Prevent Individual or Institutional conflicts of interest or conflicts of commitment in their assigned duties for the University;
• Disclose potential conflicts of interest to the University and adhere to any requirements created to manage or eliminate actual or apparent conflicts of interest;
• Ensure personal relationships or outside financial interests do not interfere with objective judgment in decisions affecting University employment, research, or the academic progress of a student; and
• Ensure their assigned duties for the University receive their full effort, attention, and commitment.

Outside Activities

All Faculty (Outside Activities)

The University of Massachusetts Boston campus requires an annual disclosure from all faculty members regarding Outside Activities. Per the UMass Policy on Consulting and Outside Activities (Trustee Policy T96-047), faculty members are expected to devote to the University their primary professional loyalty and to direct to the University their time and energy. As they are considered "special state employees" for purposes of the Massachusetts law governing the conduct of public officials and employees (Massachusetts General Laws Ch. 268A) however, they are permitted to engage in limited activities outside of the University during normal working hours, provided such outside activities do not interfere with their primary obligations. The University recognizes that outside activities can be of value to faculty and the University.

Foreign Influence and Engagement 

Increased concern has been expressed through both legislative actions and agency regulations about protecting national security and U.S. economic interests when taxpayer dollars fund the University’s work. It is important that we be responsible stewards of these funds and ensure that we are mindful of protecting intellectual property, as required by the terms of our funding.

A number of Federal research-sponsoring agencies have requirements for disclosing foreign engagements due, in part, to concerns about the relationship between foreign engagements and research integrity.

Foreign engagements include, but are not limited to, the following:

• Researcher employment with foreign entities or governments;
• Other positions, appointments, or affiliations with foreign entities or governments. These may include, but are not limited to, titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary);
• Consulting arrangements with foreign entities or governments;
• Receipt of other research support, contractual or otherwise, directly or indirectly, from foreign entities or governments. Examples of such support may include, but are not limited to, gifts, financial support for laboratory personnel, provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.), and in-kind contributions, e.g., office/laboratory space, equipment, supplies, or employees or students supported by an outside source;
• Researcher participation in foreign government-sponsored talent recruitment programs; and
• Current or pending participation in or applications to programs sponsored by foreign governments, instrumentalities, or entities.

Required Training

All investigators are required to complete FCOI training. The training must be completed: prior to engaging in research related to any PHS-funded research, and at least every four years thereafter; when an Investigator is new to the University; and when an Investigator is not in compliance with the FCOI Policy. UMass Boston Investigators should complete the CITI FCOI Training to comply with this requirement. Find step by step guides for CITI training here: 

• CITI: For New Users
• CITI: For Returning Users

UMASS Boston now uses single sign-on (SSO) for all CITI training. Please log in and associate your CITI training with UMASS Boston. 

Click here to log in to the UMass Boston CITI SSO link (for individuals with a UMass Boston email). 

Use the UMass Boston CITI Single Sign-On (SSO) link above. Enter your campus-wide UMass Boston email and password. Note: If you are prompted to link your existing UMass Boston CITI account to the SSO, select "Log in Through My Organization" and scroll to "University of Massachusetts Boston" (see instructions).

ORSP will not be able to release your award without confirmation that the training completed.

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Disclosing Outside Activities (OA) within Kuali COI

The University of Massachusetts Boston has integrated the Kuali Conflict of Interest (COI) module within Kuali eRA to receive and manage a range of disclosures including Conflict of Commitment, Financial Conflict of Interest, and foreign engagements and research integrity. The question-and-answer format enhances the ability of the Office of Sponsored Research and Programs (ORSP) to advise and guide faculty. Once completed, an OA approval request is routed electronically to the corresponding Dean, Department Head, or Provost as appropriate. Disclosing Outside Activities electronically through Kuali COI is preferred if the faculty member is federally funded.

INSTRUCTIONS: How to submit to create a disclosure in the Kuali COI module.

Additional Questions and Training please contact ORSP-Disclosures@umb.edu

Resources

• NIH FCOI Policy Notice
• NIH FCOI Training Module
• NIH FCOI Frequently Asked Questions
• DHHS Final Rule

Questions?

ORSP is available to provide advice and assistance to any individual on the interpretation of these requirements and the applicability to a specific situation. Please direct any questions to ORSP.