What is the electronic Conflict of Interest annual certification process?

Once a year, the UI requires certain employee groups (described below) to submit an annual electronic certification to indicate whether they have potential conflicts of interest or commitment related to their university responsibilities.

Who needs to complete an eCOI Annual Certification?
  • All UI employees engaged in research, defined as being named as “key personnel” on a UI routing form submitted to Sponsored Programs or an IRB application.
  • All UI Health Care faculty, Professional and Scientific (P&S), and Staff Nurses and Allied Health Professionals (SEIU) staff, as well as regular Merit staff with appointments of 50% or more in revenue-generating units (regardless of pay level).
  • Outside of UI Health Care, all UI Faculty and Staff members with 50% or greater appointments in the following categories:
    • Regular Faculty (tenured, tenure-track, clinical-track, research-track, instructional-track)
    • Regular P&S staff
    • Regular Merit staff who work in revenue-generating units
  • All university officials as defined by the policy on Institutional Conflict of Interest in Human Subjects Research, including:
    • Administrators with faculty appointments (e.g., associate provosts, associate vice presidents, DEOs, directors)
    • Institutional officers (e.g., president, executive VP and provost, vice presidents, treasurer, deans, university librarian)

Has the population of employees who must submit an annual certification changed?

Yes, the population has expanded. All regular P&S staff with appointments of 50% or more, and regular Merit staff with appointments of 50% or more in revenue-generating units, will now be required to submit the annual electronic certification, beginning on June 1, 2025. 

This change does not affect current UI Health Care employees. The faculty population required to submit an annual certification has not changed.

When does this change take effect?

The new population of staff members will be required to submit the annual electronic certification beginning on June 1, 2025. This change does not affect current UI Health Care employees or faculty. 

Employees who have submitted in previous years (as outlined above) should continue to do so as usual. Annual certifications are due by April 30 of each year.

What happens when a faculty or staff member submits an eCOI Annual Certification?

The certification asks questions to determine whether the employee has any outside interests, conflicts of interest, or conflicts of commitment to disclose. If an external interest is identified, the submitter will be asked additional questions to gather more details. This part of the disclosure process is called an External Activity Report.  

What happens when a faculty or staff member submits an External Activity Report?

Disclosures of External Activities will be reviewed by central university offices, including University HR. 

Disclosures that may require a management plan will be sent to the associate dean (for faculty disclosures) and senior HR leader (for faculty and staff disclosures) in the employee’s respective college/division for additional review. 

If needed, a management plan will be developed. Management plans are developed in partnership between the associate dean, senior HR leader, and the employee’s administrative supervisor. The employee will be engaged in the conversation prior to the filing of a plan. 

While very few activities that represent, or appear to represent, a conflict are actually prohibited, disclosure allows for potential and actual conflicts to be reviewed and managed appropriately.

Are employees negatively affected by having a management plan put in place?

No. Employees may need to have conversations with their supervisors or HR representatives if a management plan is deemed necessary. The goal of a management plan is to ensure that university decisions are made in the best interests of the institution without influence due to the conflict of interest.

Do I still need to complete the annual certification and disclose outside activities if I already have a management plan on file with UI Health Care or my college/division?

Yes. The annual certification and disclosure process is required by campuswide university policies. 

Are employees required by UI policy to disclose conflicts of interest using this process?

Yes. All UI employees are required to disclose conflicts of interests. Employees as defined above are also required to certify annually to ensure that the university is aware of any potential conflicts of interest and is able to manage them appropriately. 

Who can I contact with questions regarding conflict of interest?