Rationale for updating the policy

At the request of the Vice President for Research, the Conflict of Interest Office conducted a lengthy review of the University's Individual Financial Conflict of Interest Policy: 1-006 to determine if 1) University employees were adequately complying with policy, and 2) the University COI policy was congruent and consistent with other University policies (specifically, but not limited to, the Health Sciences Industry Relations Policy: SR 1-006, the Remunerative Consulting and Other Employment Activities: 5-204), Utah state law (Utah Public Officers' and Employees' Ethics Act), and federal requirements (e.g., see Foreign Affiliations). The results of the review highlighted areas of concern that prompted changes to the COI policy. Additionally, new rules and updated definitions provide clearer guidance for University employees.

Main changes to the COI policy (Revision 12)

The following changes were made to the COI policy to ensure better compliance; consistency with other University regulations, state law, and federal requirements; and clarity of existing requirements:

1. A required annual disclosure through the University's Business Relationship Reporting for:
   1. Faculty members (excluding emeritus, visiting and adjunct faculty);
   2. Staff employed at the manager level or above; and
   3. Staff with purchasing authority or delegated purchasing authority, including account executives and their delegates, staff authorized to use a PCard, and staff authorized to make purchases through UShop.
2. Zero-dollar threshold for disclosing financial relationships that are reasonably related to an employee's job responsibilities.
3. Three new rules to provide guidance in each of the domains covered by the policy
   1. Research
   2. Scholarly or Educational Activity
   3. Transactions
4. Updated definitions

Next Steps: Implementing the new policy

The Individual Financial Conflict of Interest Policy: Policy 1-006 (Revision 12) takes effect on July 1, 2020. The COI Office and Committee will provide the following educational resources for University employees:

1. Please check the Research Education (REd) website for available courses and discussion groups.
2. Please contact the COI Office to request a virtual meeting for you or your unit.

Beginning in early Fall 2020, the COI Office in collaboration with Cynthia Best (Associate Dean in the School of Medicine) will begin notifying employees subject to the annual disclosure requirement to update their financial disclosures. Employees who are required to submit financial disclosures and have never submitted a disclosure in Business Relationship Reporting can contact the COI Office for additional guidance concerning training and the disclosure process.