University Conflict of Interests Disclosure
The University of Tennessee’s Fiscal Policy FI0125, on Conflict of Interests, requires all regular faculty and staff to disclose certain outside interests and activities. These disclosure requirements help prevent or minimize conflicts between an employee’s outside interests and his or her university responsibilities. Outside interests may include activities such as ownership or employment in an external business venture, serving on a non-profit or for-profit board of directors, etc.
The policy now has two parts: Part l is for all regular (benefits-eligible) university employees and Part ll (provisions required to comply with Public Health Service regulations governing PHS-funded research projects, including NIH projects).
Part I - Most employees will fall only under Part I of the policy. All regular employees will now be required to complete the Part I form annually by October 31st.
The University has created an electronic Outside Disclosure Form to expedite this process. Please click on this link https://app.perfectforms.com/player.htm?f=8OuEAgwH to complete your conflict of interest form. After completing the form, users will be asked to enter the e-mail address of their immediate supervisor. Your completed form will then be routed electronically through the approval process. The complete policy and the Part I disclosure form are at the following website: http://policy.tennessee.edu/fiscal_policy/fi0125/.
A Help Guide explaining the process is available at the following link: http://treasurer.tennessee.edu/forms/DOI-Instructions.ppt. Please note that you will need your personnel number (not your UTC ID) to complete the form; you can find your personnel number on your Online Pay Statement accessible at: Online Pay Statement
Part II - Additional required disclosure for investigators on PHS-funded research projects. Employees, students, and others will be required to complete a disclosure form under Part ll of the policy if they are deemed to be an investigator on a PHS- funded research project (including NIH research projects). For employees, this form will be in addition to the Part l form. New PHS regulations require that investigators complete training on the new PHS regulations and the University’s Conflicts of Interest Policy and then complete the new Part ll form before a new award date on a current project and before a proposal for new funding can be submitted. Campus research and business officers will determine who will be required to complete the new disclosure form under Part II and when the initial disclosure must be made. Requirements to update the initial disclosure are stated in Part II of the Conflicts of Interest Policy. This form is also now paperless and employees will be directed to it by answering a question on form one. The complete policy and disclosure forms for Part II are at the following website: http://policy.tennessee.edu/fiscal_policy/fi0125/. Please click on “Forms” in the Topics box to locate the forms.
All Investigators who are planning to submit grant/contract applications or those who will receive new funding from current projects on or after August 24, 2012 are required to:
- Complete conflicts of interest training on the new PHS regulations and the University’s Conflicts of Interest Policy prior to engaging in activities related to any PHS-funded research project. The primary source of training will be through the Collaborative Institutional Training Initiative (CITI). The CITI Program offers a conflicts of interest mini-course that provides training in regulations related to financial conflicts of interests. Please contact your campus Office of Research for the website.
- Complete the Financial Interest Disclosure Form - Investigators Participating in or Proposing PHS-Funded Research. Please make sure your department head or immediate supervisor reviews and signs the form. The form can be completed and saved before printing.
Frequently Asked Questions (FAQs)
All regular UTC faculty and staff (exempt and non-exempt) are asked to complete a paperless OID form whether or not they have anything to disclose form at this time. Our goal is to have an online disclosure from 100% of employees for better tracking and record-keeping purposes. Completing a paperless OID form will ensure that you are in compliance with UT policy and that neither you nor your supervisor receive subsequent reminders or follow-up messages.
The Office of Human Resources can offer assistance with the online process and to answer any questions you may have about the procedure. Please contact Kendra Biggs in the UTC Office of Human Resources if you have questions regarding attendance of these computer lab sessions.
At the end of the form, you enter the name and email address of your immediate supervisor. You will receive an auto-generated email confirming that you’ve completed the form, and the individual identified as your supervisor will receive an auto-generated email prompting them to review the information you have submitted and identify whether they believe there to be any actual or perceived conflicts based on the information you have provided. Supervisors will complete their section of the “paperless” form and identify if others need to review the form prior to the form proceeding to the Chief Business Officer (or designee). When your supervisor has completed and submitted her/his review, you will receive a second auto-generated email with details about your supervisor’s review and next steps.
Please work with all regular faculty & staff who report to you to ensure that they complete the paperless form and route it to you for administrative approval. Once an employee has completed and submitted the paperless form, you can review and approve it using the following steps:
Check your email inbox for an email from “UT Forms” with the Subject Line “Findings, Supervisor Notification, Outside Interest Disclosure Form for [NAME OF EMPLOYEE]”. This email will be automatically-generated by the system for each employee who completes the paperless form. Employees completing the form will need to enter your email address to facilitate routing, so please make sure they know your email address.
Click on the link at the end of the auto-generated email. This will take you to the supervisor’s section of the paperless form, as shown in the screen shot. In the upper left-hand corner, you can click on “Review Employee Data” to review all the information on the employee’s disclosure form.
After you have reviewed the employee’s disclosure form, check the appropriate boxes to indicate how they responded to the questions and if there is the possibility of a conflict of interests in your opinion. If you answer “yes” or “unsure” please provide a brief explanation in the space provided. NOTE: the employee will be able to see any comments you enter here.
Enter YOUR NAME and email address in the fields for “Department Head/Supervisor” name and email address.
If additional review and approval is needed from another supervisor before the form is routed to the HR office and the Chief Business Officer, click on the “yes” radio button and enter the name and email address of the additional approver.
Click on the “Submit” button at the bottom of the page when you are ready for this to progress to the next approver. The employee will receive an auto-generated email that includes your determination and any comments you may have added.
The UT System has developed a power point “Help Guide” that explains the process from a system-wide perspective and can be accessed at the following link: DOI-Instructions UTC (2).ppt
The paperless disclosure system addresses Part I of the policy, the part that applies to all employees. The Outside Interest Disclosure required to comply with Part I is the same as in the past, this version is just paperless. Part II of the policy only applies to a smaller subset of employees who are involved in preparing, submitting, implementing, or evaluating grant-funded projects that fall under the auspices of the Public Health Service’s Financial Conflict of Interest regulations (including NIH, HRSA, CDC, MCH, and other federal health-focused agencies as well as other sponsors such as the American Heart Association who have adopted the PHS regulations). Part II requires a separate disclosure form in addition to the general OID discussed in Part I. If you are unsure whether or not Part II of the policy may apply to you, please contact the Office of Research & Sponsored Programs (email@example.com) for guidance.