Annual Attestation

Annual attestation is the process to ensure compliance to the University of Utah’s Individual Financial Conflict of Interest Policy 1-006. This policy requires certain employees to file a financial disclosure to report whether they have any external business relationships (that reasonably appear to be related to their professional responsibilities to the University), so that potential financial conflicts of interest can be properly identified.

An updated disclosure must be filed at the start of each academic year (after July 1).

These individuals must file a disclosure (even if they have nothing to report) in the Business Relationship Reporting (“BRR”) system, which is the institutional tool the University uses for financial disclosure processes across campus:

Faculty (excluding emeritus faculty and visiting faculty who do not participate in other triggering activities)
Adjunct faculty in Health Sciences and all adjunct faculty involved in scholarly or educational activities
Staff employed at the manager level or above
Staff with purchasing authority or delegated purchasing authority
- For example, account executives and their delegates, staff authorized to use an institutional credit card (e.g., Purchasing Card or PCard), staff authorized to make purchases through UShop, and staff authorized to arrange travel expenses through Concur. (Additional information can be found on the COI Office’s webpage – Guidance for Purchasers.)
Employees who participate in scholarly or educational activity, or transactions
Research Investigators

See detailed instruction documents and help at https://oris.research.utah.edu/brr.php.

NEW SOFTWARE

The software for BRR was upgraded in January 2025 to a revised software supported by the Office of Research Information Systems (ORIS). This upgraded system has increased data security and offers enhanced functionality over time. The site will look different, but all previous data will be maintained.

As of August 2026, there are new questions which must be completed.

TRAINING

Training is required this year for everyone due to recent policy revisions. You must complete training before filing a disclosure.

COMPLIANCE FOR FILING A DISCLOSURE

Supervisors and other leadership can now help track disclosure compliance of their employees by accessing the ‘Compliance (Annual Attestation)’ tab in BRR. This feature is live and access to these individuals is already granted, based on HR data. Your dashboard there is tailored to your role in the organization structure. View disclosures from your group by clicking into the Attested column for more details. Please follow-up with employees who do not have a recent disclosure on file since July 1.

Additional personnel (as appropriately determined by supervisors) can be granted access to the dashboard if other support within the group is needed to assist in compliance monitoring (contact COI@utah.edu to request the “Compliance Champion” role and explain which org ID you are requesting).

HEALTH SCIENCES DIRECT SUPERVISORS MUST APPROVE BUSINESS RELATIONSHIPS

For those who are part of Health Sciences, BRR is now the mechanism for direct supervisors to document their review and approval of their employee’s disclosures. This can only be performed by those who were listed as the discloser’s direct supervisor during the disclosure process. See the 'Supervisor Reviews’ tab in BRR to perform this activity. If the wrong direct supervisor was listed by mistake or if supervisors have questions about the review process, please log at ticket at https://app.healthcare.utah.edu/conflictInfo/index.

Direct supervisors from other areas of campus should continue to independently document their reviews in writing (for example, via email) until this feature is released further.

See more about the process for employees to obtain approval for external business relationships on the COI Office’s FAQ page.

CONTACTS FOR SPECIFIC ISSUES/QUESTIONS:

General Process, Disclosure Requirements, and Policy
Contact the Conflict of Interest Office (COI@utah.edu)
Research Security and Foreign Relationships
For example, what must be disclosed and other guidance for international business?
Contact the Research Security Office (RSO@utah.edu)
Supervisor Reviews for Health Sciences employees
For example, how should supervisors make the determination to approve relationships?
Contact Health Sciences Compliance Services (https://app.healthcare.utah.edu/conflictInfo/index OR regulatorycompliance@hsc.utah.edu)
IT and Website Issues
Contact the Office of Research Information Systems (ORIS@utah.edu)
OR submit a help ticket at: https://uofu.service-now.com/it?id=uu_catalog_item&sys_id=eac6e8451bd41e90a359a9b5604bcbee
BRR FAQs and Guides Page:
https://oris.research.utah.edu/brr.php