Disclosure & Reporting - Conflict of Interest

Financial Disclosure Requirements

An Investigator or Employee must submit a Financial BRR Disclosure Form in University's online Business Relationship Reporting (BRR) system with complete and accurate information about all Financial Relationships that reasonably appear related to their professional responsibilities to the University. Individuals completing this disclosure who are not employees of the University of Utah should report Financial Relationships that reasonably appear to be related to their responsibility to their employer or profession.

The University, rather than the investigator or employee, is responsible for determining if a Financial Relationship is relevant to a particular project or activity.

The University maintains records related to disclosures and management of financial conflicts of interest for at least five years after the completion of the research.

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Disclosures Need to be Updated Regularly

Investigators and many Employees are required to update their BRR Disclosure Form at least annually and within thirty (30) days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new Financial Relationship that is related to their professional responsibilities to the University.

Disclosure of Travel

All travel or related expenses paid or reimbursed by a foreign entity must be disclosed.

Additionally, Investigators engaging in federally funded research must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) that is related to their responsibilities to the University in accordance with federal sponsors’ requirements.

UUHS Faculty and UUHS Managers must disclose ALL reimbursed or sponsored travel related to their Financial Relationships and Consulting Relationships.

Travel expenses reimbursed through the University are exempt from disclosure.

Confidentiality and Public Accessibility About Conflicts of Interest

The Conflict of Interest Policy indicates that the University will comply with federal and state laws that may require public disclosure of information relating to identified conflicts of interest. This includes making certain information available to the public about the conflicts of interest of senior/key personnel participating in research funded by the Public Health Service (or other federal sponsors with substantially similar requirements, such as the U.S. Department of Energy). This information will be made available on a publicly available web site. Additionally, the University may require public disclosure on the web site as part of a conflict management plan when appropriate under other circumstances, such as conflicts of interest involving human subjects research.

Self-Reporting of Potentially Conflicted Activities

Sponsored research administered by the Office of Sponsored Projects (OSP) and Human Subjects Research administered by the Institutional Review Board (IRB) include built in mechanisms for conflict of interest review by the COI Office. These activities do not need to be self-reported. Other activities subject to oversight by the Individual Conflict of Interest Policy (1-006) may not have mechanisms to create automated reviews. Therefore, it is the responsibility of potentially conflicted individuals to submit an Conflict Reporting Form when their University activities are reasonably related to their Financial Relationships. These activities include, but are not limited to:

Unsponsored, or internally funded, Research that is not administered by OSP or IRB,
Scholarly or Educational Activity,
Business Transactions including, but not limited to, purchases, contracts, subawards, license negotiations, lease agreements, etc.

Annual Compliance Reports

When the Individual Conflict of Interest Committee determines that a conflict of interest exists and necessitates a management plan, the plan may the managed individual to submit reports annually to certify their compliance with the approved management plan. Annual Compliance Reports can be submitted in ERICA.

Non-Compliance: Retrospective Reviews and Mitigation Reports

Whenever a conflict of interest is not reported or managed in a timely manner, the University may complete a “retrospective review” of the investigator’s activities and the research project to determine whether any research conducted during the time period of the noncompliance was biased in the design, conduct, or reporting of such research. Retrospective reviews are required if the research is sponsored by the Public Health Service (PHS) or another federal sponsor that has adopted substantially similar requirements (such as the U.S. Department of Energy). If bias is found, the University must notify the federal sponsor promptly and submit a mitigation report.

Reports of potential non-compliance or policy violations can be made to the COI Office directly, on-line using EthicsPoint, or through the Ethics and Compliance Hotline (888) 206-6025.

Peer Monitor Reporting

Some management plans require individuals with conflicts of interest to name a non-conflicted peer or supervisor to monitor certain activities related to the conflict of interest. This link provides additional guidance for individuals serving as Peer Monitors.

ERICA

Access and submit COI forms related to specific projects

Business Relationship Reporting

Complete CoI Training

File or update your financial disclosure

University of Utah Public Disclosures

Review the public disclosure list of conflicts of interest

iNSTITUTIONAL About ICOI PUBLIC DISCLOSURES INDIVIDUAL

Conflict Reporting Form

Self-report a COI related to job responsibilities

EthicsPoint

Anonymously report a non-compliance or a policy violation

Peer Monitor Reporting

Review a list of questions to consider in your report