History of Dearborn's COI/COC Policy
This is a brief history of the development and approval of Dearborn's Conflict of Interest (COI) and Conflict of Commitment (COC) implementation polices for faculty and staff.
In March 2002, the Office of the Vice President for Research announced to UM's Research Associate Deans that "We have known -- and have heard -- that there is a need for clearer
and more accessible policy and procedural information on various university conflict of interest and commitment policies" and requested a listing (but not copies) of any and all related policy statements from academic units. There were few such policies found on the Dearborn campus at that time and the Director of Research and Sponsored Programs (Dearborn's "Research Associate Dean") reported to the Provost, "[in the past] I haven't [come accross] a situation where I thought [Dearborn] should have our own policy. What may be missing is an understanding by our faculty of [existing UM] policies. . . ."
By November 2003, the University's administration determined that the Standard Practice Guide statement of COI policy needed revising and that each academic unit, including the Dearborn and Flint Campuses, needed to draft individual implementation policies and disclosure procedures for COI and COC. In response to the charge put forward by Ann Arbor's Provost and the Vice President for Research, Dearborn's Provost replied, "I am in agreement with the direction you propose for review and refinement of the University's current conflict of interest and conflict of commitment policies. I would recommend Drew Buchanan, Director of Research and Sponsored Programs, as the representative from UM-Dearborn to work with you on this review. In addition to the groups that you reference, I would ask that input be solicited from the UM-Dearborn Faculty Senate."
A renewed interest in the University moving forward with COI/COC came about around June of 2005. The Chancellor appointed the Director of Research and Sponsored Programs to be Dearborn's point of contact with Ann Arbor on drafting Dearborn's policies and was also appointed to the central Policy Review Group charged with reviewing and recommending for approval all UM policy documents.
The Dearborn Campus has chose, in January 2006, to draft a single COI/COC Implementation Policy for faculty and a separate policy for staff that would apply to all Dearborn academic and non-academic units. The development process included input from individual faculty and the Faculty Senate, examination of existing policies at UM and other institutions, and presentations to deans and senior officers.
The faculty and staff documents were eventually approved by Dearborn's Faculty:
- College of Business--February 1, 2007;
- College of Education, Health, and Human Services--February 16, 2007;
- College of Arts, Sciences and Letters--March 7, 2007;
- College of Engineering and Computer Science--April 6, 2007.
Starting September 1, 2008, the Campus began roll-out of the policy, which included meeting with Senior Officers and their direct reports, selected staff reporting to these directors, and faculty of Dearborn's schools and colleges. A disclosure form for Dearborn faculty as-needed and annual reporting was used starting about November 1, 2008. In August 2012, key personnel on National Institutes of Health (NIH) and other Public Health Service (PHS) grant applications were required by PHS policy to disclose all outside financial interests related to their University job. The University used an early version of M-Inform (used by the Medical School) to insure that it complied with PHS regulations.
On July 1, 2013, the University of Michigan rolled out the current version of M-Inform to be used university-wide for all COI disclosures by faculty. M-Inform is to be used by all Dearborn faculty to annually disclose outside financial interests related to their University positions and to update the annual disclosure throughout the year as needed; M-Inform is to be used by Dearborn staff at any time an apparent or perceived conflict of interest situation arises. Dearborn's COI/COC implementation policies for faculty and staff were updated to reference M-Inform and to clarify the policy in certain places.