Conflict of Commitment and Interest

1. Conflict of Commitment and Interest Report of Non-University Activities (RNUA)

2. 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

3. 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

4. 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.

5. PHS Agencies • 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

6. Other Agencies Following PHS Disclosure • American Heart Association • American Cancer Society • Arthritis Foundation • Susan G. Komen Foundation • Juvenile Diabetes Research Foundation • Alliance for Lupus Research • Lupus Foundation of America

7. 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)

8. 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)

9. 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.

10. Who Must Report? • Faculty • Academic staff • Postdoctoral associates • Part-time as well as full-time

11. 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.

12. 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.

13. 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 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

14. 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.

15. Disclosure & Request for Prior Approval • Fill in required information at top of form • Part I: Conflict of Commitment & Interest Disclosure • Six - Yes/No Responses • 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

16. Disclosure & Request for Prior Approval • Part II: Explanation of Non-University Activities • If 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

17. 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

18. 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”

19. 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.

20. 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.

21. 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.

22. Disclosure & Request for Prior Approval • Part IV: Response to Employee Disclosure • Completed by Primary Reviewer • Section has 2 parts • Part 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 maypresent conflict – primary reviewer adds management plan and forwards for 2nd review • Activities Denied & staff member should not engage in activity – requires second level of review

23. Disclosure & Request for Prior Approval • Part V: Review and approval by Primary Reviewer • Sign and date • Part VI: Additional Review and Approval

24. 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.

25. 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

26. 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

27. 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.

28. 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.

29. Summary (1 of 2) Be familiar with the University’s Policy on Conflicts of Commitment and Interest and requirement of the RNUA process Informyour academic staff about the COCI Policy and RNUA process Reviewstaff requests for involvement in non-University activities whenever an RNUA form is filed

30. Summary (2 of 2) • ReviewRNUAs submitted by academic staff, including written statements when required • Askquestions of academic staff about their non-University activities. • CompletePart IV and V of RNUA (check boxes and attach referenced explanations)

31. 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