The COI Process

Conflict of interest disclosures are required by all UNM researchers who can affect the planning, supervise the conduct of, or participate in the reporting of UNM research. This generally includes the Principle/Lead Investigator, named Key/Senior Personnel, and folks such as senior graduate students or postdoctoral fellows, who have a supervisory role over UNM research.

The primary time for disclosing and reviewing COI is soon after the call for annual disclosures, although new disclosures and updates to COI occur throughout the year. Upon receipt of an affirmative disclosure, ORIC triages the disclosure for review, determines a risk level, and assigns it to COI Committee members as needed.

The Committee will then decide whether the disclosed interest is of the level that requires management and issue a management plan or decision memo accordingly. If a management plan is issued, the Committee will also assign a Plan Monitor to oversee that management plan and assist the Investigator with following its stipulations.

The Management Plan

We have found that the best way to manage conflicts without unduly impeding either research projects or investigators’ outside interests is by issuing a management plan. As outlined above, the management plan is developed in response to the COI Committee deciding a research COI rises to the level involving enough risk to research objectivity that a neutral person needs to review the conflict in view of the Investigator’s research activities.

The plan outlines the conflicts under review, confirms that they are reportable and require management, and assigns a plan monitor. It then outlines the stipulations that the investigator must abide by and the duties of the monitor.

Once the management plan has been signed by both the investigator and the monitor and is returned to ORIC, the conflict is considered managed.

The Monitor Report

Once a year, or more frequently if required by the management plan, ORIC will ask the monitor to complete a monitor report. This is our confirmation that the conflict has been managed according to the stipulations of the management plan. This generally requires a meeting between the investigator and monitor to discuss the provisions of the management plan and how they have (or have not) been met. The monitor then completes a short narrative report to ORIC to discuss the results of the meeting. ORIC provides the template for this report.

Why was I chosen as a monitor?

In general, the monitor is the chair of the department in which the investigator resides. In some cases (e.g., collaboration with the chair, the chair themselves has a conflict) the monitor may be the Associate Dean for Research in the school housing the department; if the researcher is the dean or other administrator, it moves up the OVPR and so on. In very rare cases, the ADR from another college will be selected if there is no one within the investigator’s school or department who is appropriate to monitor the investigator. At UNM, monitoring the research of investigators with a COI is part of the duties of departmental and school/college administrators.

What are my duties as a monitor?

The duties of a monitor are relatively simple.

1. Review the contents of the management plan (ideally with the investigator) so that you are familiar with the situation and what needs to be managed. Sign the management plan to confirm that you have done this.
2. Once a year, or more often if requested by the COI committee, meet with the investigator to discuss the progress of the management plan.
3. If necessary, help facilitate the stipulations of the management plan.
4. If you become aware of any further potential research COI, please inform ORIC as soon as possible and encourage the investigator to report them.
5. Inform ORIC if an investigator is not abiding by the management plan.

For more information, please refer to our COI monitor training document.

FAQs