The university requires some employee groups (described below) to submit an annual electronic certification once per year to indicate whether or not they have potential conflicts of interest or commitment related to their University responsibilities.
- All UI employees engaged in research, which is 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, P&S and SEIU staff, as well as Merit exempt employees with 50% or greater appointments (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),
- P&S staff compensated at Pay Levels 7 and above (see ePersonnel File in UI Employee Self Service for Pay Level),
- P&S staff compensated at Pay Level 6 and below who are administrative supervisors.
- Institutional Conflict of Interest in Human Subjects ResearchAll University Officials as defined by the policy on
- Administrators with Faculty Appointments (e.g., Associate Provosts, Associate Vice Presidents, DEOs, Directors), and
- Institutional Officers (e.g., President, Executive VP & Provost, Vice Presidents, Treasurer, Deans, University Librarian).
Yes. All Non-Health Care P&S staff compensated at Pay Level 6 and below who are administrative supervisors will now be required to submit the annual electronic certification, beginning on May 3, 2021.
This change does not affect current UI Health Care employees.
All P&S staff members compensated at Pay Level 6 and below who are administrative supervisors will be required to submit the annual electronic certification beginning on May 3, 2021. This change does not affect current UI Health Care employees.
Employees who have submitted in previous years (as outlined above) should continue to do so as they normally would. Certifications are due by April 30, 2021.
The certification asks several 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 in the annual certification process, the submitter will be asked additional questions in order to gather additional details. This part of the disclosure process is called an External Activity Report.
- Disclosures of External Activities will be reviewed by the Conflict of Interest in Research office and 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, and 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.
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 University without influence due to the conflict of interest.
Yes. The annual certification and disclosure process is required by campus-wide University policies.
Yes. There are two new types of questions that are now included as part of the annual certification process:
- A question has been added regarding whether an individual has an outside personal relationship with someone over whom they exercise supervisory authority. The addition of this question will assist with identifying possible Conflicts of Interest in Employment (Nepotism) cases that may require a management plan. More information can be found here.
- Questions have also been added asking about international engagement. This addition will assist with identifying possible risks to research integrity and security which may require conflict of interest management or adherence to other federal regulations.
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.