Conflict of Commitment and Interest - PowerPoint Presentation

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Conflict of Commitment and Interest

Report of Non-University Activities (RNUA)

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Conflict of Commitment and Interest (COCI)

TopicsCOCI Policy (http://research.uillinois.edu/policy/coci)Report of Non-University Activities (RNUA

) (http://research.uillinois.edu/rnua)Primary Reviewer ResponsibilitiesAdministrative Review and ApprovalQ & A

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The University of Illinois Policy on Conflicts of Commitment and Interest was revised effective August 24, 2013, to meet changes in Public Health Services regulations.

http://research.uillinois.edu/policy/coci Changes include:Civil service staff, students, and medical residents no longer exempt when working under PHS funding

Defines Significant Financial Interests at $5,000 thresholdSubrecipients of grants included under policyMandatory training for PHS sponsored researchersRetrospective review and reporting

COCI Policy Update

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COCI Guidelines for Civil Service Employees: Requirements and suggestions have been added to the guidance on the OVPR website (http://research.uillinois.edu/coci/civil-service

) Rule 16.01 of the Policy & Rules for Civil Service Staff require disclosure of activities that may present a potential conflict with university roles & responsibilities.Link at the website to “Conflict of Interest Disclosure Form for Civil Service Employees” has been added.Additional guidance and contact information has been added.

COCI Policy Update

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PHS Agencies

National Institute of Health (NIH)Food and Drug Administration (FDA)Centers for Disease Control (CDC)Agency for Healthcare Research and QualityAgency for Toxic Substances and Disease RegistryHealth Resources and Services AdministrationIndian Health Services

Substance Abuse and Mental Health Services Administration

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Other Agencies Following PHS Disclosure

American Heart AssociationAmerican Cancer SocietyArthritis FoundationSusan G. Komen FoundationJuvenile Diabetes Research FoundationAlliance for Lupus ResearchLupus Foundation of America

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A “

conflict of interest” arises when an academic staff member is in a position to influence directly or indirectly University business, research, or other decisions in ways that could lead to gain for the academic staff member, the staff member’s family (

spouse or children), or others to the detriment of the University.

(

occurs

during and beyond

the contract period)

The basic principles remain the same

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A “conflict of commitment” exists when external activities are so demanding as to interfere with the staff member’s responsibilities to the unit to which the individual is assigned, to students, or to the University.

(occurs only during the contract period)

The basic principles remain the same

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Why Conduct Annual Reporting?

RNUA is the University’s implementation of state and federal law and University policy.Federal funding requires a written and enforced COI policy to ensure objectivity of research.State agencies/entities require that our policy be adequate and properly monitored/enforced.Compliance with University policies is included in terms of employment.

There are sanctions for noncompliance.

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Who Must Report?

FacultyAcademic staffPostdoctoral associatesPart-time as well as full-time

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What Must Be Reported?

All non-University income-generating activities (regardless of net revenue) ANDAll other external activities that may present a conflict of commitment with University responsibilities.Includes non-University income-generating activities that occur outside the contract period.

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Is anything exempt from reporting?

Yes. See the University Policy on Conflicts of Commitment and Interest (see Part III, Section E)ExamplesPreparing, publishing, or presenting scholarly or creative works, including software, even if honoraria, stipends, or royalties may be providedServing as a reviewer or editor for a scholarly journal, even if financial consideration is provided

Earning income from passive investments such as interest or dividends from banks, mutual funds, or stocks and bondsParticipating in a clinical practice plan approved by the University of Illinois Board of Trustees.

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When?

The state law requires forms to be submitted annually. However, Forms should be updated in the interim if significant changes in activity occur. Advance written approval of all external income-producing activities is required.Current Reporting Deadlines

Sept. 15, 2014 – RNUA forms available online and employees notifiedOct 27, 2014 – Complete forms

are due to Primary Reviewers

Nov.

17, 2014

– ALL checklists and forms

are due

to the

Provost’s

Office

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How?

The Report of Non-University Activities form is available online at http://research.uillinois.edu/rnua/forms-instructions. Download and

complete the form, then submit a signed copy to your Primary Reviewer for administrative review and prior approval.

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Disclosure & Request for Prior Approval

Fill in required information at top of form Part I: Conflict of Commitment & Interest Disclosure

Six - Yes/No ResponsesPaid instructor another college/university

Income producing activity, financial, fiduciary role outside organization in field or research

Income producing activity, financial, fiduciary role outside

organization that does business with the University

Income producing activities with students or other University employees

Other than above, other conflict of commitment/interest with appointment that may include financial, non-financial or fiduciary

Member of immediate family has ownership interest with outside entity that does business with the University

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Disclosure & Request for Prior Approval

Part II: Explanation of Non-University ActivitiesIf any yes answers in Part 1, must complete Part II

If only one activity reported, then complete only Part II that follows Part 1 If more than one activity is reported, use the “Part II. Additional Reporting Page for the Explanation of Non-University Income Producing Activities”

Use as many Part II supplemental pages as necessary to report all activities

Part III: Affirmation

Sign and date form(s)

Submit the form(s) to Primary Reviewer

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Responsibilities of Primary Reviewer

Identification of conflicts is facilitated by the annual disclosure process, currently using the Report of Non-University Activities

The Primary Reviewer works with the academic staff member to identify and evaluate potential conflicts and to manage or eliminate them

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Responsibilities of Primary Reviewer

Primary Reviewers hold primary responsibility to manage Conflict of Interest (COI)/Conflict of Commitment (COC)

Ensure all faculty and other academic staff participate fully and adhere to timeline

Emphasize “request for prior approval” as opposed to mere “reporting”

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Responsibilities of Primary Reviewer

Collect completed report forms from all academic staff on your checklist

Date stamp completed forms as academic staff submit them.

Notify the Provost’s Office if any of your academic staff members’ names are not listed on the checklist.

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Responsibilities of Primary Reviewer

If a staff member on your list is out of the country, on a leave of

absence, on sabbatical, or on sick leave, please note the absence and anticipated return date on the checklist. The Primary Reviewer is

responsible for ensuring that

individual completes and submits a

form upon

return

.

Carefully

review RNUA forms as they are turned in each fall, and

as

updated forms are received during the year

Engage in discussions as needed to clarify reported activities

and

to follow up on activities that you know of that may

have

been overlooked.

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Responsibilities of Primary Reviewer

Verify that other employees named in activities have also disclosed, if required to

report.

Respond

within 14 days of receiving an academic staff’s request for approval of

activities.

Complete and Sign Part IV and Part V on page 2 of the RNUA form.

If you deny any activities or don’t reach voluntary agreement, provide staff member the opportunity to respond before transmitting the form to the next level.

Follow through on conflict management plans.

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Disclosure & Request for Prior Approval

Part IV: Response to Employee Disclosure Completed by Primary Reviewer

Section has 2 partsPart A: Check if no conflict exists

Part B: Includes 3 possible responses

Does not present conflict, no second level review needed

Activities approved

AND/OR

may

present conflict

– primary reviewer adds management plan and forwards for 2

nd

review

Activities Denied

& staff member should not engage in activity – requires second level of review

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Disclosure & Request for Prior Approval

Part V: Review and approval by Primary Reviewer Sign and date

Part VI: Additional Review and Approval

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When evaluating activities reported, consider whether….

Educational programs or the progress of students or other staff might be detrimentally affected by the reported non-University activities.

University research might be inappropriately influenced by external interests or involvements reported.Dissemination of knowledge might be unduly constrained.

Public resources might be used for private gain.

Reported activities involve

an excessive time commitment that would diminish the employee’s commitment or service to the University.

teaching outside the University, unless assigned or approved.

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Hypothetical Example: Outside Consulting

HR employee Jones is a paid, part-time consultant for ACME Academic Personnel Services, Inc.

Jones provides advice to University Search Committees on consulting firms specializing in academic hiring.Jones requests to work Monday through Thursday only, to allow her to travel for consulting work on the weekends.

HR Department has a graduate assistant, who is also paid independently by Jones for an additional 5 hours a week to help with clerical tasks associated with the consulting business

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Key Factors

Conflict of interest between University work and private consulting.

Possible conflict of commitment if significant work functions occur on Fridays and must be delegated to other staff.

Involvement of HR employee and graduate student employee in the same department and extra hours.

Where is the boundary between the University work and consulting work?

Potential misuse of University resources due to inability to separate activities

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FAQ’s

My NSF subaward is paid through UIS. Do I have to report this subaward? No

I have a 100% appointment with UIUC and also teach part-time for UIS. Do I have to report this on my RNUA?

No

I have a 50% appointment with UIS that is in two different departments. Do I have to complete an RNUA for each department?

No, chose the department with the largest percentage of your appointment, indicate on your form that you are reporting only to this department, but that you also have an appointment with department __ for ___% time, and notify the other department that you completed with the first

. The form will be forwarded to the second primary reviewer after it is completed

by the first.

The formatting is off when I print the RNUA form. Can I use the printed copy anyway?

No, turn off the shrink-to-fit feature on your printer.

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FAQ’s

The RNUA form has a signature button on the top right hand corner of the page. However, it doesn’t do anything when I click on the button. How do I add an electronic signature?

Currently, the electronic signature feature does not work. Until otherwise informed it will be necessary to print the form and sign it.

Do adjuncts need to complete the RNUA?

Yes

Do I need to report anything prior to the beginning of my initial appointment?

You are not required to report any activities prior to the beginning of your initial appointment with UIS unless you were under an appointment with one of the other UI campuses immediately preceding your appointment at UIS

.

I work full-time (12 months) at SIU

School

of

Medicine

and have a 25% appointment at UIS as an adjunct. Do I report my prospective number of days that I will request during this contract period?

Yes.

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Summary (1 of 2)

Be familiar with the University’s Policy on Conflicts of Commitment and Interest and requirement of the RNUA process

Inform your academic staff about the COCI Policy and RNUA process

Review

staff requests for involvement in non-University activities whenever an RNUA form is filed

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Summary (2 of 2)

Review

RNUAs submitted by academic staff, including written statements when required

Ask

questions of academic staff about their non-University activities.

Complete

Part IV and V of RNUA (check boxes and attach referenced explanations)

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Primary Reviewer Information Guide

Stay on top of proceduresCommunicate

Meet processing deadlinesSept. 15, 2014 – RNUA forms available online and employees notifiedOct 27, 2014 – Complete forms and checklists due to Primary Reviewers

Nov. 17, 2014 – ALL checklists and forms due to the Provost’s

O

ffice