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Conflicts of Interest FAQ

Frequently Asked Questions

What are some examples of interests that should be disclosed?
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You should disclose any known financial interests that you or members of your family have in any of these areas:

  • Any University purchase or procurement of goods or services (whether or not pursuant to a formal contract) or in any investment or loan made by the University.
  • Ownership interest in a company that does business with ̽̽.
  • Serving as a board member of an entity that has business dealings with ̽̽.
  • Having a relationship, paid or unpaid, with another institution of higher learning. 
  • Providing consulting services to outside entities.
  • A donor that contributes a monetary gift or gift-in-kind designated to be in support of the Employee's scholarly activities.
  • Employment outside of ̽̽ while employed by ̽̽.
What's the difference between a conflict of interest (COI) and a financial conflict of interest (FCOI)?
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  • A conflict of interest (COI) is any interest that will, could, or is intended to lead to a profit or increase in the income or net worth of an employee and/or their family member.
  • A Financial Conflict of Interest (FCOI) means that it could directly and significantly affect the design, conduct, or reporting of eternally funded research. More information can be found in the Financial Conflict of Interest in Sponsored Research Policy.
What is the difference between a financial conflict of interest (FCOI) and a significant financial interest (SFI)?
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Nothing. FCOI means that there is a Significant Financial Interest (SFI). It is defined/regulated by the federal government. FCOI’s only apply to PI’s and Investigators and only apply to those interests of the PI/Investigator, their spouse, and/or their dependent children that reasonably appear to be related to the PI’s/Investigator’s institutional responsibilities. More information can be found in the Financial Conflict of Interest in Sponsored Research Policy.

I'm an investigator and I've already filled out my FCOI disclosure. What else do I need to do?
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  • Nothing until you receive notification.
  • You will need to fill out a new disclosure form when you receive your notification from ̽̽Click. 
Do I need to disclose every interest that I have?
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  • You are only required to disclose those relationships and/or activities (interests) that you or a member of your family have that could create a conflict. Keep in mind, however, that should you fail to disclose a potential conflict, the University cannot provide assistance in the event there are allegations of impropriety for activities that are not disclosed. If you are unsure, you may want to disclose it.
  • Depending on the nature of the conflict, the University may need to take personnel action in accordance with University policies and/or collective bargaining agreements if an interest was not disclosed and it turns out to be a conflict.
Do I need to disclose all of my investments and holdings?
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  • No. You are only required to disclose your investments and holdings in a company if (1) you or a member of your family controls the interest, and (2) the company is related to your institutional responsibilities. For example, if you are able to influence the decision to enter into an arrangement with the company, or if you participate in the recommendation or selection of a company, or if you interact with the company as part of your ̽̽ job, you should disclose it.  If you’re not sure, contact your for guidance.
  • You do not need to disclose mutual funds or other retirement accounts where the plan decides where to invest and what stocks to buy.
  • You do not need to disclose interests held by members of your family unless (1) and (2) above is true. Investments by your adult children, for example, do not need to be disclosed unless there is a nexus between the investment and your ̽̽ job. 
Where do I go to submit my disclosure form?
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  • ̽̽ upgraded its system to include COI/COC disclosures.
  • Go to the ̽̽Click – FCOI. Click on the big green button that says “LOGIN”. From there, you enter your ̽̽ credentials to sign in and fill out your disclosure form.
My work at the University is supported by a gift in which I am named as a beneficiary. Do I need to do anything to be in compliance with this policy?
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  • You are only required to disclose those interests and activities that you or a member of your family has that could create a conflict. To protect yourself and the University, if you are unsure, you may want to consider disclosing it. There is no harm in over-disclosing; however, should you fail to disclose a relationship or activity and it turns out that it is a conflict, the University cannot provide assistance in the event there are allegations of impropriety.
  • Additional information can be found in ̽̽’s Gift Policy.
I have an invention that will be licensed through ̽̽ innovations. What is required of me under this policy?
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If you have an equity interest, serve as an officer or are involved in a management role for the third party to which ̽̽ Innovations is considering licensing the invention, you must disclose this through ̽̽ Click. Following submission, your reviewer will determine whether a management plan is needed. If so, this will be referred to the Office of Compliance and Privacy Services. Someone will work with you, your reviewer and/or the Office of General Counsel to develop a management plan. If sponsored research is involved, it may also be referred to Research Integrity for additional review.