Due May 31: Update Disclosures, Answer New Foreign Engagement Questions

udisclose certification how-to

FAQs on UDisclose and Foreign Engagement

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  • What is the UDisclose System?

    UDisclose is the electronic system the University uses, allowing individuals to disclose external financial interests, foreign engagements and other disclosures as required by University policies and federal and state regulations.

  • How often do I have to update my UDisclose certification, including the foreign engagement questions?

    Disclosures are required on an annual basis, though you can update your disclosures any time throughout the year. Any information you enter is saved and will be available for editing the next time you access the UDisclose System.

  • I am the Principal Investigator of a research study. Does my study team need to disclose? If so, is this only for faculty members?

    Study team members who are not faculty do not need to disclose at this time unless they are designated to a new award/study/contract under the University’s current interest disclosure process. As the PI, you are responsible for designating team members who are substantially involved in the design, conduct, or reporting of your project. Each team member, including faculty, will answer the foreign engagement questions once a year.

  • I’ve never disclosed before, do I need to register in the system?

    A UDisclose profile has most likely already been created for you. Just log into the system to complete a new disclosure. If you are unable to access the system, please complete a new account request format the bottom of this webpage.

  • Are my disclosures kept confidential?

    Yes, only certain employees bound to our confidentiality policies will be able to access and review your information. Also, to the greatest extent possible, your information will not be shared outside the University. Some examples where the information may be shared include subpoenas and when required by a sponsor in a grant application or as a term of the award.

  • Do you have UDisclose System user guides available?

    Yes, user guides with step-by-step instructions and screenshots are available here with additional information available from the UDisclose System website and the DRM website. Please remember that you can always contact us (DRM@miami.edu or 305-243-0877) for assistance.

  • I am applying for research funding. Does my disclosure impact my application?

    Some of the information included in your disclosure may be required to be included in your application. For example, most sponsors require the disclosure of all appointments; whether or not remuneration is received or if the appointment is part-time, visiting, honorary or adjunct. Additionally, when “other” support (also called current and pending support) is submitted, the “other” support must include all sources of support for your research and scholarship (including support that is not routed through the University). This support may be in the form of funding to your lab, or it may also be people, equipment, and labs in another location. Our Office of Research Administration (ORA) website offers additional information about funding agencies’ disclosure requirements, including the National Science Foundation (NSF), National Institutes of Health (NIH), National Aeronautics and Space Administration (NASA), Department of Defense (DOD), and the Department of Energy (DOE).

    It is important to ensure all appointments and other support are disclosed in the application. Failure to disclose may result in loss of funding, suspension from receiving federal funding, or even criminal charges. If you have questions about what is required to be included in your application, please contact ORA.

Additional information is also available here: Foreign Engagement and Influence and Guidelines for Foreign Entity Relationships

Frequently Asked Questions (FAQs)

Version 2.0 | Last updated: Dec 8, 2020

General background

1. Why does UM require the disclosure process?
2. Who needs to disclose their outside professional activities (OPAs)?
3. I did not engage in any OPAs. Do I need still need to disclose?
4. How often do I have to update my UDisclose certification?
5. What happens if a disclosure is not made in a timely fashion?
6. What do staff members need to complete?
7. Where is the disclosure data stored? Who has access to it?
8. Do voluntary or part time faculty members need to disclose?
9. Why does UM review all research projects and related outside interests as though they were PHS-funded projects?
10. Why does UM have a financial disclosure threshold that is more stringent than required by Federal regulations?
11. Do members of UM’s leadership have to make disclosures?
12. Why should I disclose private information about my outside interests to UM?

UDisclose System access

13. How do I get access to the UDisclose System?

Proxy designation in the UDisclose System

14. I have been designated as a “Proxy” for someone else. What does that mean?
15. Is the UDisclose Proxy the same as an IRB7/eProst Proxy?
16. Are there any limitations to a Proxy’s role?
17. How do I designate or change a Proxy in the UDisclose System?
18. How many UDisclose Proxies can I have at once?
19. Does the Proxy need to be a team member on a project or can I designate anyone?
20. Will my UDisclose Proxy be able to view all of my disclosures, research studies, etc.?
21. Does the Proxy receive email reminders to enter or update information in the system, or does the PI receive such notifications?
22. Who should the Proxy contact with questions regarding the UDisclose system?
23. Does the UDisclose System work on ALL browsers (i.e. Google Chrome, Internet Explorer, and Firefox)?

Outside interests to be disclosed to the University

24. Why is the disclosure process more convenient in the UDisclose System?

Outside Professional Activities (OPAs)

25. What is an OPA?
26. Is there anything improper about performing OPAs?
27. Are there entities/payors that are excluded from the regulations?
28. How do I disclose to UM that I have a relationship with an outside entity?
29. What if I have multiple types of interests with the same entity, for instance consulting and teaching? Do I need to create a separate entry for each?
30. What if I don’t know the exact amount of compensation for an OPA at the time that I disclose? What do I enter?
31. Do I disclose the OPA when performed or when I am compensated?
32. How long do I have to disclose a newly acquired OPA or FOI?
33. Am I required to disclose an OPA when the payment is made to the University?
34. I have an appointment at the VAMC. Is that considered an OPA?
35. If I have a 9-month appointment at UM. Do I disclose OPAs done in the summer?
36. I am on sabbatical or on leave. Do I need to disclose?
37. Why do I have to disclose unexercised stock options?
38. When do I need to enter compensation/reimbursement for travel?

Institutional Responsibilities (IRs)

39. What is an Institutional Responsibility (IR)?
40. How do I know if an interest is related to my IRs?

Financial and Obligatory Interest (FOI)

41. What is a FOI?
42. Is there anything improper about having a financial or obligatory interest (FOI)?
43. What is the difference between disclosure of an OPA and disclosure of a FOI?
44. Do I need to separate entries for my spouse and/or dependent children if more than one of us has an FOI with the same entity?
45. Do I need to report changes in value of stock or other similar interests?

Travel

46. In the DPS, there was a travel section. Where do I enter travel in the UDisclose System?
48. Who needs to disclose travel?
49. When do I need to enter compensation/reimbursement for travel?
50. Do I have to disclose travel that does not relate to an IR?
51. Can I have reimbursed or sponsored travel not related to an IR?
52. My award includes money to attend a meeting. Where do I disclose it?

Projects that will require research certifications

Triggering Events

53. What is a “Triggering Event”?
54. What is the purpose of Triggering Events?
55. How is it determined whether a person is substantively involved in the design, conduct, or reporting of research/sponsored educational activities, and thus qualifies as an “investigator”?
56. What is a UDisclose Project ID?
57. What is the source for the pre-populated information?
58. As a PD/PI, how do I add (or delete) people to my team?
59. As PD/PI, how do I determine the compliance status of investigators that I want to add to my project?
60. Why does the UDisclose System not list all of the awards or contracts on which I work?

Human Subject Research (HSR) Studies

61. How are HSR studies listed in the UDisclose System?
62. Which HSR studies require research certifications from the team members?
63. Who is included on the study team; who must make disclosures?
64. What must be done to complete a research certification for HSR studies?
65. Why are my ongoing studies not listed in the UDisclose System?
66. What is an Institutional COI?
67. How do I get additional information?