Conflicts of Interest (COI) & Outside Activities - Policies and Disclosure Requirements : Research and Engagement : UMass Amherst

NOTICE! The Department of Energy (DOE) has finalized their updated Conflicts of Interest and Conflicts of Commitment Rule and it is effective August 17, 2026. Please see the DOE section below for further details.

A Conflict of Interest (COI) exists when it can be reasonably determined that an investigator's personal financial concerns could directly and significantly influence the design, conduct, or reporting of government funded research activities. Faculty and staff of the University of Massachusetts Amherst have an obligation to maintain the objectivity of their research, avoiding any conflict of interest. All UMass Amherst investigators are expected to comply with university and sponsor-specific COI policies by disclosing any significant financial interests prior to or at time of proposal submission and to update them as required.

The University of Massachusetts Board of Trustees (BOT) Conflicts of Interest and Commitment Policies and guidance documents can be found here.

Conflict of Interest FAQs

Sponsor Specific Financial Conflict of Interest FCOI Policies

Many Federal and non-Federal sponsors require Financial Conflicts of Interest disclosures (FCOI). FCOI disclosure requirements are part of the terms and conditions of awards from NASA, NSF, PHS/NIH, and DOE. Details on each are included in the corresponding accordion sections below.

Disclosure Submission

Conflicts of Interest disclosures are submitted through the Kuali COI module within Kuali Research. The disclosure form includes questions related to the above university BOT policies, Sponsor-specific FCOI regulations, Outside Activity Approvals, and Foreign Engagement. See instructions below.

Note: Disclosures under Massachusetts General Law Chapter 268A: Conduct of Public Officials and Employee are not made through Kuali. For guidance, contact the Massachusetts State Ethics Commission.

Disclosure Review

The Conflict of Interest Disclosure Process Flowchart visually describes the UMass Amherst COI disclosure process. The Office of Research Compliance (ORC) reviews all Kuali COI disclosures under the appropriate sponsor or university BOT policies. The review process is often collaborative, with ORC reaching out to researchers for clarification, to provide guidance, and to discuss next steps should a real or potential conflict be identified.

Questions?

COI regulations, policies, reporting requirements: Hilary Reid, COI Analyst, Office of Research Compliance, @email
Kuali COI, disclosure review, timeline, etc.: Melinda LeLacheur, Research Compliance Program Coordinator, Office of Research Compliance, @email

Submitting a Disclosure in Kuali COI

CITI COI Training Enrollment Instructions

Outside Activity Disclosure

Faculty members are expected to devote to the university their primary professional loyalty and to direct to the university their time and energy. 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 UMass Policy on Consulting and Outside Activities (BOT T96-047 ) requires faculty to submit approval requests for Outside Activities (OAs) annually.

How to disclose an OA and have it routed for pre-approval:

OA approval requests are submitted using the Kuali COI disclosure form. There is a specific section designed to capture information about these activities so they can be routed for pre-approval. OA pre-approval requests are routed to the corresponding department head, dean, or provost for review and approval. Once in place, notification is sent to the approver and the requester/submitter.

Outside Activity Disclosure FAQs:

Why does the university require faculty and others to disclose outside activities and outside financial interests?

University faculty and other personnel are Commonwealth employees and thereby subject to the Massachusetts ethics regulations. Faculty and others engaged in teaching and academic research have a negotiated “carve out” from these regulations, subject to certain requirements for the university to review, approve, and manage potential conflicts of interest stemming from outside activities. This allowance is in place to foster technology transfer and economic development activities that benefit the Commonwealth. Because university employees are compensated using taxpayer dollars, we must strive to embody and model the highest ethical standards for our students and Massachusetts taxpayers. The Amherst campus leadership reminds faculty and others that these types of entrepreneurial activities, when disclosed and approved properly, are points of pride and celebration as they represent the university’s commitment and obligation as a public land grant university to economic development and community service.

Outside financial interests (unrelated to an outside activity) must also be disclosed, not only to comply with Massachusetts ethics regulations, but also Federal regulations which may be applicable based upon one’s funding sources for research and sponsored projects.

What specific activities need to be disclosed?

Generally, researchers should disclose ongoing engagements with outside entities where that engagement is related to an individual’s institutional duties, such as editorship service (if not awarded through UMass); short- or long-term consulting positions; and paid or unpaid service on board of trustees, science advisory boards, etc. These activities and the associated financial interests (e.g., consulting income, equity) should be disclosed, reviewed, and approved by the university. In addition, outside financial interests unrelated to outside activities such as equity, royalties, and stock options must be disclosed.

Monetary thresholds for disclosure depend upon one’s external funding. For PHS funded researchers, remuneration or equity in a public entity totaling more than $5,000 in the previous 12 months must be disclosed, as well as any equity at all in a private entity. For NSF and other Federally-funded researchers, the threshold is $10,000 or 5% equity (public or private). If faculty have no Federal funding, the threshold is $10,000 or 1% equity for non-clinical research and $1,000 and any equity for clinical research. Faculty who work with human subjects and who are conflicted have a higher bar for approval to engage in the research because university policy presumes the default action is to deny approval to ensure the health and welfare of human subjects involved in the research.

What if I start a business?

The university, as a land grant institution, has a primary commitment to the transfer of knowledge and, by extension, the economic well-being of the Commonwealth. Entrepreneurial activity is a component of this commitment and a key goal for research at public universities throughout the United States and thus faculty are encouraged to pursue entrepreneurial activities. However, as full-time employees of the Commonwealth, faculty and other personnel owe a primary “fiduciary obligation” to the university as our employer and to the taxpayers of Massachusetts who fund the university. For this reason, if an outside business conflicts with (because it overlaps with) areas of expertise or university responsibility, an individual may be at risk of an ethics violation by participating in that activity without disclosure and approval through the university processes. Research and Engagement professionals in the Office of Research Compliance and the Technology Transfer Office are available to support faculty start-up efforts with business envisioning, entrepreneurial guidance, and assistance with conflicts management.

Where do I get help?

The Office of Research Compliance can assist faculty and other university personnel with actual or apparent conflicts of interest, or in properly documenting, as needed, any outside activities related to one’s institutional duties. Please let us help! @email

Department of Energy (DOE) FCOI Training and Disclosure Requirements

Notice: New Department of Energy (DOE) Conflict of Interest and Conflict of Commitment Rule - Effective August 17, 2026

In July of 2026, the U.S. Department of Energy (DOE) issued updated regulations regarding conflicts of interest and conflicts of commitment. The new federal rule has a very short implementation timeline and takes effect on August 17, 2026.

Full DOE Policy - Financial Assistance Regulations - Conflict of Interest and Conflict of Commitment Policy Requirements

The UMass Amherst Office of Research Compliance (ORC) is actively updating our campus procedures and refreshing our electronic disclosure system (Kuali COI) to align with these requirements. ORC is also working on training updates and revisions to the UMass system policy

Because the new rule expands what must be reviewed and when, this update directly impacts how and when DOE-defined covered individuals submit disclosure, especially prior to grant proposal submissions.

Key Changes:

Conflicts of Commitment Are Now Covered
In addition to financial interests, disclosures now include outside professional commitments. This includes titled academic or professional positions with outside entities (such as visiting or honorary roles at foreign institutions), participation in foreign talent recruitment programs, and agreements with problematic data-sharing restrictions.

Mandatory Reporting of Foreign Government-Related Conflicts
DOE now requires the University to identify and explicitly report any actual, potential, or apparent conflicts involving foreign governments, foreign state-owned entities, or foreign-funded programs directly within proposals submitted to DOE.

Disclosures Must Be Reviewed BEFORE Proposal Submission
Due to the new reporting rule, the University is required to review all investigator disclosures prior to submitting a proposal to DOE. To prevent delays in submitting your grant applications, covered individuals with reportable interests will need to complete or update their Kuali COI disclosures with sufficient lead time before the proposal deadline.

What you need to do:

Planning a DOE Proposal Soon?
If you or your key personnel are submitting a DOE proposal on or after August 17, please plan to log into Kuali COI and complete your updated disclosure as early in the proposal preparation window as possible. Proposals cannot be submitted to DOE until required screening reviews are completed.

Watch for System Updates
We will send a brief notification as soon as the updated DOE disclosure form is live in Kuali COI.

Training
ORC is working on updating the CITI COI training module to cover the new DOE requirements.

The DOE Interim Conflict of Interest policy described below is in effect until August 17, 2026 at which time the new policy replaces it.

The DOE Interim Conflict of Interest Policy is applicable to each investigator who is planning to or is participating in a project funded under a DOE financial assistance award including National Nuclear Security Administration (NNSA) funding applications. It does not apply to Office of Indian Energy or Phase I Small Business Innovation Research (SBIR)/Small Business Technology Transfer (STTR) applications and financial assistance awards. The policy outlines definitions of Investigator, FCOI, and Significant Financial Interest (SFI).

FCOI Disclosures

Investigators proposing to or receiving funding from DOE must submit a disclosure through Kuali COI at time of application, even if there are no SFIs to report. Disclosures must be updated annually and within 30 days of a new SFI or discovery of one not previously included.

FCOI Training

Investigators must complete two online, on-demand CITI courses, “Overview of COI and COC” and “COI Under DOE” prior to engaging in research related to any DOE financial assistance award. Conflict of Interest (COI) Training Info & Instructions.

This training must be renewed at least every four years, as well as immediately under the following circumstances:

Institutional FCOI policies change in a manner that affects Investigator requirements,
An Investigator is new to UMass Amherst.
UMass Amherst finds that an Investigator is not in compliance with the established FCOI policy or management plan

Resources:

National Aeronautics and Space Administration (NASA) FCOI Disclosure Requirements

National Science Foundation (NSF) FCOI Disclosure Requirements

NSF encourages the increased involvement of academic researchers and educators with industry and private entrepreneurial ventures but recognizes that such interactions carry with them an increased risk of conflicts of interest. See NSF Proposal & Award Policies and Procedure Guide (PPAG 23-1): Chapter IX. Conflict of Interest Policy for further details.

NSF sponsored Investigators (and those submitting application to NSF) are required to disclose all significant financial interests (SFI) of the investigator (including those of the investigator's spouse or dependent children) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF or in entities whose financial interests would reasonably appear to be affected by such activities. Key definitions, including that of Investigator, Conflict of Interest and Significant Financial Interest (SFI) can be found in the NSF policy linked above.

The UMass Amherst Policy for Compliance with NSF Financial Conflict of Interest Disclosure Regulations can be found here.

FCOI Disclosures:

Investigators who are planning to propose to NSF must submit a Kuali COI disclosure, even if there is nothing to disclose, no later than time of application submission, annually, and "as new reportable significant financial interests are obtained" (Chapter IX.A.3).

FCOI Training:

Though NSF does not require FCOI training, there are two on-line, on-demand CITI courses that are available and cover the policy. Investigators are encouraged to complete the “Overview of COI and COC” and “COI under NSF” courses prior to engaging in research related to any NSF financial assistance award. See above section link to training instructions.

Note: Responsible Conduct of Research Training is also a term and condition of NSF funding and is also provided through the CITI platform. See Responsible & Ethical Conduct of Research Training for details.

Public Health Service (PHS)/National Institute of Health (NIH) FCOI Training and Disclosure Requirements

42 CFR Part 50 Subpart F, Promoting Objectivity in Research is the PHS regulation establishing standards that provide a reasonable expectation that the design, conduct, or reporting of research funded under any of their Agencies will be free from bias resulting from any Investigator’s conflicting financial interest. This includes grants and cooperative agreements.

Under this policy, NIH requires recipient institutions and their investigators (except Phase I SBIR/STTR applicants and recipients) to fully comply with all FCOI requirements. Key Definitions, including that of Investigator, FCOI, Institutional Responsibilities and Significant Financial Interest (SFI) can be found at NIH Financial Conflict of Interest.

The BOT Policy for Promoting Objectivity in Biomedical Research (Doc. T96-039) is the related FCOI compliance plan for the Amherst campus.

Note: NIH has also updated their policy regarding what must be disclosed on the Biosketch and Other Support. This update is detailed in NIH Pre-award and Post-award Disclosures Relating to the Biographical Sketch and Other Support.

FCOI Disclosures

Investigators and other project personnel responsible for the design, conduct or reporting of the research must disclose all SFIs that are related to their Institutional Responsibility and are received from and/or held by an entity outside the institution. Investigators, including subrecipient Investigators, must disclose all foreign financial interests. Disclosure submission in Kuali COI is required at the time of application, even if there are no SFIs to report, annually, and within 30 days of a new Significant Financial Interest or discovery of one not previously disclosed.

FCOI Training

Investigators and other project personnel responsible for the design, conduct or reporting of the research must complete CITI Financial Conflict of Interest training (either basic or the refresher if it has been taken before) prior to engaging in research related to any PHS-funded grant or contract and at least every four years, as well as immediately under the following circumstances:

Institutional FCOI policies change in a manner that affects Investigator requirements,
An Investigator is new to UMass Amherst;
UMass Amherst finds that an Investigator is not in compliance with the established FCOI policy or management plan.

Conflict of Interest (COI) Training Info & Instructions

Resources:

Offices, Agencies, Organization, and Foundations subject to the PHS/NIH FCOI disclosure policy

United States Department of Agriculture (USDA)

Have a concern related to research and scholarly activities? Use our anonymous reporting line:

Anonymous Reporting Line Details

Conflicts of Interest (COI) & Outside Activities - Policies and Disclosure Requirements