Transcript Slide 1

Conflict of Commitment and Interest
Report of Non-University
Activities (RNUA)
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Conflict of Commitment and Interest (COCI)
Topics
• COCI Policy (http://research.uillinois.edu/policy/coci)
• Report of Non-University Activities (RNUA)
(http://research.uillinois.edu/rnua)
• Primary Reviewer Responsibilities
• Administrative Review and Approval
• Q&A
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COCI Policy Update
• 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 threshold
• Subrecipients of grants included under policy
• Mandatory training for PHS sponsored researchers
• Retrospective review and reporting
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COCI Policy Update
• 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.
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PHS Agencies
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National Institute of Health (NIH)
Food and Drug Administration (FDA)
Centers for Disease Control (CDC)
Agency for Healthcare Research and Quality
Agency for Toxic Substances and Disease Registry
Health Resources and Services Administration
Indian Health Services
Substance Abuse and Mental Health Services
Administration
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Other Agencies Following PHS Disclosure
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American Heart Association
American Cancer Society
Arthritis Foundation
Susan G. Komen Foundation
Juvenile Diabetes Research Foundation
Alliance for Lupus Research
Lupus Foundation of America
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The basic principles remain the same
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)
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The basic principles remain the same
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)
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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?
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Faculty
Academic staff
Postdoctoral associates
Part-time as well as full-time
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What Must Be Reported?
• All non-University income-generating activities
(regardless of net revenue) AND
• All 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)
• Examples
Preparing, publishing, or presenting scholarly or creative
works, including software, even if honoraria, stipends, or
royalties may be provided
Serving 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 bonds
Participating 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 incomeproducing activities is required.
• Current Reporting Deadlines
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Sept. 15, 2014 – RNUA forms available online and employees notified
Oct 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/formsinstructions.
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 Responses
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Paid 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 Activities
• If any yes answers in Part 1, must complete Part II
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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
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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 parts
1. Part A: Check if no conflict exists
2. Part B: Includes 3 possible responses
i. Does not present conflict, no second level review needed
ii. Activities approved AND/OR may present conflict – primary reviewer
adds management plan and forwards for 2nd review
iii. 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….
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Educational programs or the progress of students or other
staff might be detrimentally affected by the reported nonUniversity activities.
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University research might be inappropriately influenced by
external interests or involvements reported.
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Dissemination of knowledge might be unduly constrained.
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Public resources might be used for private gain.
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Reported activities involve
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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
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HR employee Jones is a paid, part-time consultant for ACME
Academic Personnel Services, Inc.
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Jones provides advice to University Search Committees on
consulting firms specializing in academic hiring.
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Jones requests to work Monday through Thursday only, to
allow her to travel for consulting work on the weekends.
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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
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Conflict of interest between University work and private
consulting.
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Possible conflict of commitment if significant work functions
occur on Fridays and must be delegated to other staff.
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Involvement of HR employee and graduate student
employee in the same department and extra hours.
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Where is the boundary between the University work and
consulting work?
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Potential misuse of University resources due to inability to
separate activities
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FAQ’s
1. My NSF subaward is paid through UIS. Do I have to report this
subaward? No
2. I have a 100% appointment with UIUC and also teach part-time for UIS.
Do I have to report this on my RNUA? No
3. 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.
4. 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
5.
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.
6. Do adjuncts need to complete the RNUA? Yes
7. 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.
8. 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)
1. Be familiar with the University’s Policy on
Conflicts of Commitment and Interest and
requirement of the RNUA process
2. Inform your academic staff about the COCI Policy
and RNUA process
3. Review staff requests for involvement in nonUniversity activities whenever an RNUA form is
filed
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Summary (2 of 2)
4. Review RNUAs submitted by academic staff,
including written statements when required
5. Ask questions of academic staff about their
non-University activities.
6. 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 procedures
• Communicate
• Meet processing deadlines
• Sept. 15, 2014 – RNUA forms available online and
employees notified
• Oct 27, 2014 – Complete forms and checklists due
to Primary Reviewers
• Nov. 17, 2014 – ALL checklists and forms due to the
Provost’s Office
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