| Related Policy | Version Effective Date | Review Cycle | Last Reviewed | Procedures Contact |
|---|---|---|---|---|
| UMGC IV-2.00 | Sept. 14, 2026 | Every 5 years | Sept 14, 2026 | Office of the President |
- Introduction
These Procedures implement UMGC Policy IV-2.00 UMGC Policy on Conflict of Interest in Research and Development. In accordance with University System of Maryland (USM) III-1.11 Policy on Conflicts of Interest in Research or Development, USM VIII-15.00 Policy on High Impact Economic Development Activities, and the State Ethics Law, in addition to other existing USM and UMGC policies on professional commitment of faculty, outside consultancy, and conflict of interest, these Procedures sets forth the requirements to obtain such exemptions from the State Ethics Law when UMGC collaborates with external entities for research and development. - Scope
All UMGC officials and employees shall comply with these Procedures. - Definitions
- Designated Official: The UMGC staff member(s) tasked with reviewing the disclosure form.
- Harmful Interest: An interest which is found by the Designated Official to be so influential as to impair impartiality in the conduct of research, the interpretation of the results of the research, and/or the determination of research or other professional or employment priorities.
- Relationship: Means any interest, service, employment, gift, or other benefit or relationship. "Relationship" includes any relationship of the spouse or other relative (father, mother, sister, brother, or child) of an officer or employee if such relationship would create restrictions on the officer or employee under the conflict of interest provisions of the Public Ethics Law.
- Research or development: Means basic or applied research or development and includes:
- The development of marketing of university-owned technology;
- The acquisition of services of an official or employee by an entity for research and development purposes; or
- Participation in State economic development programs.
- State Ethics Law: The law contained in the Annotated Code of Maryland – General Provisions – Title 5 – Maryland Public Ethics Law.
- Procedures
- Timely Disclosure of any Relationship
- UMGC requires timely disclosure of any relationship, defined herein, which would otherwise be prohibited by this Policy or the State Ethics law.
- Outgoing (or former) officials or employees shall take any necessary steps to ensure compliance with thisPolicy when transitioning from UMGC employment to a position at another organization or interest in such organization. Failure to do so may result in notice to the Ethics Commission.
- Review of Claim for Exemption by Designated Official
- UMGC officials or employees claiming an exemption under this Policy shall complete the disclosure form, available from the Office of Legal Affairs.
- An employee may not engage in the research and development activities until he or she receives final approval from the UMGC President.
- The Office of Legal Affairs shall forward the disclosure form to the Designated Official for review and evaluation.
- The Senior Vice President and Chief Operating Officer shall review the disclosure form submitted by UMGC staff member(s) and other UMGC officials.
- The Vice President, Global Academic Learning Enterprise & Chief Academic Officer shall review disclosure forms submitted by UMGC Faculty members and members of the divisions of Academic Affairs.
- The Designated Official in reviewing the disclosure form:
- May request further information to be disclosed;
- Shall determine whether or not the disclosed relationship represents a harmful interest; and
- Shall determine the restrictions, if any, which shall be imposed by UMGC to manage, reduce or eliminate any actual or potential conflict of interest.
- Following completion of the disclosure form review, the COO or Provost shall forward the form to the UMGC President.
- UMGC officials or employees claiming an exemption under this Policy shall complete the disclosure form, available from the Office of Legal Affairs.
- Approval of the Claim for Exemption by the President
- The UMGC President shall approve or deny the claim for exemption as described in the disclosure form. The decision of the UMGC President shall be the final decision.
- If the Designated Official determined that the disclosed relationship represents a harmful interest, then approval shall not be granted.
- Post-Approval Conflict of Interest
- If, after approval of the claim for exemption, a new or unforeseen conflict of interest arises between the UMGC employee/official and the entity engaging in research and development, the UMGC employee/official shall promptly disclose such conflict, in writing, to the Office of Legal Affairs who shall forward such disclosure to the Designated Official for processing.
- Timely Disclosure of any Relationship
- Enforcement
UMGC officials or employees who violate the Policy or Procedures may be subject to disciplinary action up to and including termination of employment. In addition, the Ethics Commission may be notified of violations of the Policy or Procedures. - Related Policies, Procedures, and References