University of Utah regulation (Individual Financial Conflict of Interest Policy 1-006) requires the following individuals to file a financial disclosure to the University, on at least an annual basis and at the start of each academic year (in August), of their external financial relationships (that reasonably appear to be related to the individual’s responsibilities to the University), so that potential financial conflicts of interest can be properly identified:
- Faculty, excluding (a) emeritus faculty, (b) visiting faculty, and (c) adjunct faculty who do not hold an appointment in a Health Sciences school or college
- Staff employed at the manager level or above
- Staff with purchasing authority or delegated purchasing authority, including account executives and their delegates, staff authorized to use an institutional credit card (e.g., Purchasing Card or PCard), and staff authorized to make purchases through UShop. (Additional information can be found on the COI Office’s webpage – Guidance for Purchasers.)
- Employees who participate in research, scholarly or educational activity, or transactions
These individuals must file a financial disclosure (even if they have nothing to report) in the Business Relationship Reporting (“BRR”) system, which is the institutional tool the University uses for conflict of interest reporting processes across campus.
INSTRUCTIONS
• Login
Please login to the Business Relationship Reporting system at the following site using your CIS/Network login.
http://BRR.utah.edu
Or, access the site through Campus Information Services by searching for ‘BRR’ or
‘COI.’
• Training
Training on conflicts of interest is required (provided in BRR) prior to filing a
financial dislcosure. Retraining is required every four years and when significant
policy changes are made.
• Definitions
You will have an opportunity to review the definitions for terms such as "Business
Entity" and "Family Member." Remember that University policy requires disclosure of
certain relationships regardless of whether you are compensated for the activity.
• Section 1: Professional, Foreign, and Financial Relationships
Only if reasonably related to your professional responsibilities at the University, you must report:
- Any employment outside of the University of Utah for yourself or your family members. “Employment” is defined as a position that generates an income and includes self-employment.
- Any professional (including unpaid) and financial relationships for yourself and your family members for the past 12 months andany future relationships for the next 12 months. For the academic departments and colleges/schools, a copy of the disclosure will be routed to your chair/chief for approval. Faculty and staff should update their disclosure in BRR within 30 days of acquiring a new financial relationship.
All employees having professional relationships with foreign entities and/or foreign
individuals (as defined in that section in BRR) are required to disclose those interests
by answering “Yes” to the existence of a foreign relationship and complete the required
additional questions.
• Section 2: Intellectual Property
Records of University-owned intellectual property should automatically populate in
your disclosure from the Partners for Innovation, Ventures, Outreach & Technology
(PIVOT) Center databases. Please review for accuracy and make additions as necessary,
including to make a report of non-University owned intellectual property that is related
to your professional responsibilities at the University.
• Section 3: Travel
If you have had travel or related expenses paid by a foreign entity, you are required
to disclose travel details in this section.
If you are an investigator working in research with the United States Public Health Service (PHS) or another federal sponsor that has adopted requirements that are substantially similar
to PHS requirements (such as the Department of Energy), you are required to disclose your sponsored travel in this
section. In addition, Health Sciences faculty and managers are required to disclose all sponsored
travel that is reasonably related to their financial or consulting relationships.
• Section 4: Certify
Once all information has been entered, you will review and certify your disclosures.
Contact the following groups if you have any questions about the certification process:
Technical Questions: support@ufis.atlassian.net
Process Questions: Conflict of Interest Office coi@utah.edu or (801) 587-3232
Thank you for your help with this annual process.
University of Utah Conflict of Interest Office
COI@utah.edu
801-587-3232
https://coi.utah.edu