Instructions

Instructions for the Disclosure Profile System (DPS)

The UM Conflict of Interest (COI) policy stipulates that prior to submission of a proposal/contract on which they will be a team member, and at least once a year, Investigators (all faculty, staff, trainees and students, as well as external subcontractors/ subawardees) that could perform research and sponsored scholarly and/or educational activities must disclose to UM all interests and relationships that are related to their Institutional Responsibilities. The disclosure process is completed using the Disclosure Profile System (DPS). The DPS is divided into “Interest” and “Project” sections. The “Interests” pages are utilized by DPS users to submit disclosures (Outside Professional Activities (OPAs), Financial or Obligatory Interests (FOIs), Institutional Responsibilities (IR), and Travel events). The “Project” pages are used by Project Directors/Principle Investigators (PD/PIs) to designate teams on sponsored projects, and by all team members to answer questions about their sponsored and human subject research projects.

The process begins by asking users four questions about their rank and responsibilities at UM. The users’ answers determine what disclosures they need to complete. Once the four answers are certified, users are guided by the DPS through the remaining disclosure process. At each stage, users certify that the information they entered is correct, and they acknowledge that they will update the system within 30 days should their disclosures change.

When a notice of grant award is received by the University, the PD/PI is contacted, he/she submits information, and designates team members for that award or contract in the DPS. Once the team is designated, each team member's disclosures will be reviewed for potential relationships to the sponsored work. As new accounts will not be opened until each team member's disclosures have been reviewed, it is the responsibility of the PD/PI to enter this information into the DPS in a timely manner in order to ensure that their project/award/contract is reviewed for potential COI.

Determine what you must disclose. What best describes your status at UM?

Faculty, not involved in sponsored activities

Full-time faculty, University of Miami Medical Group members, and Miller School faculty members that could provide clinical or teaching services for UHealth who are not involved in sponsored research or scholarly/educational activities must disclose to UM their Outside Professional Activities (OPAs):

  • By the end of each calendar year
  • When the total compensation earned from a payor equals $600 dollars or more per calendar year

Additional information can be found on the Faculty Disclosure FAQs page for faculty disclosure of OPAs performed for remuneration. The DPS process for faculty not involved in sponsored work is as follows:

  1. Questionnaire; Submit
  2. Disclose OPAs $600 and over; Certify
  3. Certify not involved in sponsored work
  4. Submit answers to DPS

Once submitted, the faculty member is now complete until next calendar year unless their disclosures change or they become involved in sponsored activities.

Non-faculty, not involved in sponsored activities

In order to comply with government regulations for the submission of proposals and contracts through the University, everyone who could be involved in sponsored activities must certify their status through the DPS. The DPS process is streamlined to expedite through the system those individuals that are not faculty and not involved in sponsored work:

  1. Questionnaire; Submit
  2. Certify not involved in sponsored work
  3. Submit final answers to DPS

Once submitted, the non-faculty is now complete until next calendar year unless they become involved in sponsored activities.

Project director or principal investigator involved in sponsored activities

Initial Disclosures for Project Directors / Principal Investigators

PD/PIs will use the DPS to disclose their outside professional activities (OPAs), institutional responsibilities (IRs), and financial and obligatory interests (FOIs) that could be perceived to be related to their IRs. In addition, the PD/PI must list FOIs of his/her spouse and dependent children that are related to the PD/PI's IRs. Further, PD/PIs that are funded (even in part) by PHS monies must disclose details about travel taken that is related to their IRs.

The DPS process for anyone involved in sponsored work is as follows:

  1. Questionnaire; Submit
  2. Disclose OPAs $600 and over; Certify
  3. Disclose IRs; Certify
  4. Disclose FOIs related to IRs; Certify
  5. Disclose travel events if funded by PHS; Certify
  6. Submit answers to DPS

Once submitted, the Investigator is now complete until next calendar year unless their disclosures change or they are added to a sponsored project/award/contract team.

Additional Duties for PD/PI Once Funding is Received

New Project/Award/Contract: When a PD/PI receives notification that they will most likely receive funding, he or she must enter their project, proposal or contract into the DPS and indicate who will participate on their sponsored team. The PD/PI must know the Cane ID (C#) for each person on the team. For convenience, the DPS saves a roster of Investigators who were team members on the PD/PI's previous projects/awards/contracts from the past two years.

  1. Add Project/Award/Contract Details (populated from InfoEd)
  2. Add team members using C#s or team roster
  3. Complete Project/Award/Contract page; Save & Certify
  4. Review Project/Award/Contract table; Certify
  5. PD/PI will receive an email indicating status of team members

It is the responsibility of the PD/PI to enter this information into the DPS in order to ensure that their project/award/contract is reviewed for potential COI in a timely manner. No new accounts will be opened until each team member’s disclosures have been reviewed.

Subcontract: The PD/PI will be required to alert subcontractors or non-UM team members of the COI requirements via email at the time of proposal/contract submission. The subcontractor must inform UM in writing if the subrecipient will comply with UM's or their own institution's COI policy.

Team member involved in sponsored activities

Initial Disclosures for Team Members

Team Members (TMs) use the DPS to disclose their outside professional activities (OPAs), institutional responsibilities (IRs), and financial and obligatory interests (FOIs) that could be perceived to be related to their IRs. In addition, the TM must list FOIs of his/her spouse and dependent children that are related to the their IRs. Further, TMs that are funded (even in part) by PHS monies must disclose details about travel taken that is related to their IRs. The DPS process for anyone involved in sponsored work is as follows:

  1. Questionnaire; Submit
  2. Disclose OPAs $600 and over; Certify
  3. Disclose IRs; Certify
  4. Disclose FOIs related to IRs; Certify
  5. Disclose travel events if funded by PHS; Certify
  6. Submit answers to DPS

Once submitted, the TM is now complete until next calendar year unless their disclosures change or they are added to a sponsored project/award/contract team.

Additional Duties for Team Members Once Funding is Received

TMs will receive an email notification when added to a sponsored activity team by the PD/PI. The TM will use the DPS to agree that they are on the team and answer a few questions specific to the proposed work.

  1. Edit Project/Award/Contract
  2. Confirm* membership on Project/Award/Contract
  3. Complete Project/Award/Contract page; Save & Certify
  4. Review Project/Award/Contract table; Certify
  5. Update disclosures if necessary; Certify

* Contact the Project/Award/Contract PI if you believe you have been added to a team in error.

Once certified, the Investigator is now complete until next calendar year unless their disclosures change or they are added to another sponsored project/award/contract team. The PD/PI will receive an email indicating status of team member disclosures.

Subcontractor (non-UM team member) involved in sponsored activities

Initial Disclosures for Subcontractors / Non-UM Team Members

Subcontractors (and/or non-UM team members) must complete the consultant form to inform UM in writing if they will comply with UM’s or their own institution’s COI policy. If complying with UM’s COI policy, UM must be aware of the subcontractors disclosures at the time of proposal/contract submission. As such, the PD/PI will be required to alert subcontractors or non-UM team members of the requirements via email before submission.

If complying with UM's COI policy, contractors/consultants should complete the form, the COI training in CITI and make disclosures into the disclosure profile system (DPS). Before taking the CITI training, the subcontractor has to register for and receive an identification number (C#).

  1. Register for a C# (follow guide)
  2. Complete CITI training
  3. Make disclosures into the DPS
    1. Questionnaire; Certify
    2. Disclose OPAs $600 and over; Certify
    3. Disclose IRs; Certify
    4. Disclose FOIs related to IRs; Certify
    5. Disclose travel events if funded by PHS; Certify
    6. Submit answers to DPS

Once submitted, the subcontractor is now complete until next calendar year unless their disclosures change or they are added to a sponsored project/award/contract team.

Additional Duties for Subcontractors / Non-UM Team Members Once Funding is Received

Subcontractors will receive an email notification when added to a sponsored activity team by the PD/PI. The subcontractor will use the DPS to agree that they are on the team and answer a few questions specific to the proposed work.

  1. Confirm membership on project/award/contract team
  2. Answer project/award/contract specific questions
  3. Update disclosures if necessary; Certify

Once certified, the subcontractor is now complete until next calendar year unless their disclosures change or they are added to another sponsored project/award/contract team. The PD/PI will receive an email indicating status of team member disclosures.