Faculty and staff are required to disclose their outside interests annually in M-Inform per U-M, unit, and Public Health Service (PHS) financial conflict of interest (FCOI) regulations. Disclosing may include reporting that you do not have any outside interests related to your U-M responsibilities.
- Disclosure: A report of whether or not you have an outside interest, activity, or relationship with an external organization that relates to your institutional responsibilities.
- Disclosure Record: A "set" of one or more outside interest disclosures.
Three types of Disclosure Records are used in M-Inform to report your outside interests for unit and university review:
- Annual Disclosure
- Update Disclosure
- Research-initiated Disclosure
If you’re required to disclose:
Beginning each July 1, you receive an email reminder to complete your annual disclosure. This means:
- Reviewing the training page in M-Inform. Only you, as the discloser, can certify to completing the training.
- Reviewing and updating any previously reported outside interests
- Disclosing any new outside interests
After your annual disclosure has been reviewed by your unit and/or a COI Office:
- You complete an Update Disclosure to add a new outside interest or change an existing one. You must disclose changes to your outside interests within 30 days if you have a research project funded by an agency following the PHS FCOI regulation.
- If you are requested to disclose (but not required to per U-M, unit, or PHS regulation) by your unit or a COI Office, you start with an Update Disclosure.
During the COI review:
You may be asked to complete a Research-Initiated Disclosure to provide additional information about an outside interest(s) for unit and COI Office review when a new research activity (PAF, HUM, etc.) arises. The outside interest(s) may result in a COI Management Plan.
This procedure is divided into sections, each describing a task that may be associated with disclosing outside interests in M-Inform. To go to a specific task (e.g., removing an outside interest) click the applicable link below.
- Accessing Your Disclosure Record
- Completing an Outside Interest Disclosure
- Remove a Previously Reported Outside Interest
- Edit an Existing Outside Interest
- Modify a Reviewed Disclosure
- Add a New Outside Interest
- Restore an Inactive Disclosure
- Sign and Submit Your Disclosure Record
- If a Department Assistant Enters Your Disclosures
Log in with your uniqname and UMICH password.
If you are required to disclose, you can access your annual disclosure in one of two ways:
- By clicking the link in the email reminder to go directly into the disclosure record upon logging in; or,
- By first logging into M-Inform, and opening the disclosure record from the Home workspace.
After submitting your annual disclosure, you must access M-Inform to make changes. If you are requested to disclose, you must access M-Inform to submit an update disclosure.
This procedure shows accessing the disclosure record from the Home workspace using an Annual Disclosure as the example. If you access your Annual Disclosure via the link in the email reminder, skip to step 3.
- Select Discloser under My Roles, or verify it is selected.
- Click Click here to… on the Welcome page to open your disclosure record.
The button label will change per the disclosure status (e.g., Due Now [applies to the annual disclosure only], Under Review, Requested Changes). The most common button labels are:
- Click here to Disclose
- Click here to Complete
- Click here to Update
- Click here to make changes
Note Each July, your draft Annual Disclosure record automatically displays under Action Required if you disclosed last year, or if you did not disclose last year but are required to do so this year.
- Read the instructions on the Introduction page and click Continue. If you are working on an update disclosure, go to step 6.
- After reviewing all training materials and policies on the SFI Training page, click the I certify that I have read... checkbox indicating you’ve done so.
Note The training page only displays with the Annual Disclosure.
- Click Continue.
- Click the applicable checkbox(es) on the Triage Questions page to indicate if you have outside interests, activities, or relationships that are related to your U-M responsibilities.
- Click the applicable radio button to indicate if you have a spouse, domestic partner, or dependent(s) who is currently a U-M employee. If your answer is "Yes," enter his/her name in the field that displays.
- Click Continue.
Any disclosures from the previous year display in the Disclosures Pending Review list.
The next steps in the process will vary depending on whether you:
- Selected "None…" in step 6, or have no changes/additions (go to Sign and Submit Your Disclosure Record)
- Selected an outside interest, activity, or relationship in step 6 (go to Edit or Add, as applicable)
- Need to remove a previously reported outside interest (go to step 9)
Remove outside interests that are no longer active (i.e., the End Date is past), (e.g., the consultation has ended, etc.). Upon unit or COI Office review, the outside interest information becomes available on the Inactive tab on your Home workspace for reference.
XRemove for the outside interest disclosure you wish to delete.
- Click the Yes radio button to deactivate the disclosure.
- Enter a brief description of why the disclosure is inactive (e.g., relationship no longer applies).
- Click OK to return to the Disclosure Details page.
- The disclosure displays with a status of Pending Removal until unit review is complete.
- The delete Edit button changes to delete Re-Open, which can be used to reactivate the disclosure if it has a status of Pending Removal.
Both the Home workspace and the Disclosure Details page list outside interests that you have previously reported. When completing an Annual Disclosure, these outside interests move to a Pending Review status. Upon your review of the details (i.e., Relationship, [Estimated] Days, Total Value, etc.), edit the disclosure if necessary. You may also edit a disclosure to report:
- Travel (if required per unit rules or PHS regulations)
- Related research (i.e., how a PAF or HUM is associated with the outside interest)
- Click delete Edit to open the outside interest disclosure you wish to update.
Review each question and enter or change information for the outside interest, as needed.
There are two ways to navigate through the questions:
- Click Continue to move to the next page OR select a page from the Jump To menu to go to a specific question.
Important This procedure doesn’t show each question in the form. The following highlights those questions you will most likely change for an outside interest each fiscal year.
- Verify the Estimated Days you will spend engaged in this interest for the current fiscal year is correct, or change the value if needed.
Note This field defaults to the value reported for the previous fiscal year.
- Read the guidelines for reporting travel.
- If travel applies to your outside interest and you meet one of the guidelines (e.g., PHS), either:
Click Add (top button) to manually enter travel information in the Add Sponsored Travel Details window.
Click Add (bottom button) to upload a file (e.g., spreadsheet, unit form) with travel information.
Note The uploaded file is available for revision or deletion, as appropriate.
- Click the Yes radio button if the outside interest relates to your research activity. If yes, then answer the next question that displays.
- Click Finish to return to the Disclosure Details page.
- Repeat steps 13 - 19 for each outside interest.
If your edits/additions are complete, go to Sign and Submit Your Disclosure Record.
Once reviewed, your outside interest disclosures display in the Reviewed Disclosures list on the Disclosure Details page and in the Current list on the Home workspace. When completing an Update Disclosure, you must first move an outside interest disclosure to a Pending Review status in order to edit it.
- From the Reviewed Disclosures list, click delete Modify next to the disclosure you wish to edit.
- Click OK.
Note The disclosure moves to the Disclosures Pending Review list and can be edited as needed. See the Edit section for detailed steps.
Important Remember that you must Sign and Submit the update disclosure once edits are complete.
- Click Add Disclosure.
- Enter the name of the organization in the Select field.
Note As you type, M-Inform automatically displays a list of matching values. Click the applicable value from the list. If you cannot select the organization from the list, enter the name in the "If you are unable…" field.
- Click OK.
- Answer each question, as applicable, for the outside interest. (See the Edit section for details regarding particular questions.) Click Continue to move through the form.
- Click Finish on the last question to return to the Disclosure Details page.
- Repeat steps 1-5 to report additional outside interests, if applicable.
If your additions/changes are complete go to Sign and Submit Your Disclosure Record.
Once reviewed, disclosures with a Pending Removal status become inactive and display in the Inactive Disclosure list on the Disclosure Details page. If your activity with that entity resumes, you can restore the inactive disclosure to edit it as applicable instead of adding it as a new outside interest.
- Click delete Restore next to the inactive disclosure you wish to restore.
- Click the Yes radio button.
- (Optional) Enter a reason in the field provided.
- Click OK.
The disclosure is removed from the Inactive Disclosures section and displays under Disclosures Pending Review.
The last step in the process is to sign and submit the disclosure record from the Disclosure Details page. You sign once for all reported and removed outside interests. You must sign and submit, even if you selected "None…" on the Related Outside Interests page or had no edits/additions to make on your annual disclosure.
Important Only you, as the discloser, can sign/submit your disclosure record.
- Click Sign and Submit.
Note The system validates that all required sections have been completed. You must correct any errors before continuing.
- Read the Attestation then click OK.
The Disclosure workspace displays and the disclosure state changes to Department Review. To return to your Home workspace click My Home.
- On your Home workspace, the disclosure record now has a status of Under Review and no longer appears on the Action Required tab.
- The submitted disclosure record now displays on the In Progress tab.
- To access your submitted disclosure to make changes, click Click here to Update.
If another person (e.g., a Department Assistant) enters your outside interest disclosures, you will receive an email to log in to M-Inform to:
- Verify the information is correct
- Attest to training (Annual Disclosure only), and
- Sign and submit the disclosure record.
- Click the link in the email from the Unit Assistant to log into M-Inform.
The Introduction page of the disclosure form displays.
- From the Introduction page, click Continue to:
Refer to the procedure steps above for help.