The responses to the following responses are based on the revised Individual Financial Conflict of Interest Policy that will be effective August 24, 2012.
If you have a question that is not answered here, please submit your question in an email to firstname.lastname@example.org. We will be posting responses to new questions regularly.
A conflict of interest is a situation in which the potential exists for an individual’s personal financial interests to impair his/her judgment in the execution of his/her responsibilities to the University of Utah.
If you are not affiliated with the School of Medicine, you need to report all Significant Financial Interests for you and your Family Members (spouse/domestic partner and/or minor/dependent children) that reasonably appear related to your professional responsibilities to the University, as defined by your department or job description.
If you are affiliated with the School of Medicine, the Industry Relations Policy requires that you disclose ALL external business relationships, which includes:
For you or your Family Member
- Any equity ownership interests (e.g. stock, partnership interest, member interest) in an industry business entity, excluding ownership in mutual funds and/or pension funds.
- Any leadership position (e.g. officer, director, partner) in an industry business entity.
- Any intellectual property ownership in the products of an industry business entity.
For a publicly traded company, a Significant Financial Interest exists when the combined value of any remuneration
AND the value of any Equity Interest(s) as determined through reference to public
prices or other reasonable measures of fair market value, when aggregated for you
and your Family Members, exceeds $5,000 during twelve months.
For a non-publicly traded company, a Significant Financial Interest exists when the combined value of remuneration, when aggregated for you and your Family Members, exceeds $5,000 during twelve months OR when you or your Family Members hold an Equity Interest of any value.
Remuneration includes salary and any other payments not otherwise identified as salary (e.g., gifts, consulting fees, honoraria, paid authorship). The following sources of income are excluded from the definition of "Remuneration" and do not need to be disclosed:
- Income from seminars, lectures, teaching engagements, advisory committees or review panels sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as you and your family members do not directly control the investment decisions made in these vehicles.
- Salary, travel reimbursements or other non-royalty remuneration from the University of Utah if you are currently employed or otherwise appointed by the University.
Under certain circumstances, the University is required to make personal financial information publicly available to comply with federal and state law.
The Individual Conflict of Interest Committee routinely makes the Committee’s determinations and management plans available to:
- the individual’s University superiors (Department Chair/supervisor)
- the appropriate University offices, including but not limited to, the Office of the Vice President for Research, the Office of General Counsel, Internal Audit, Institutional Review Board, Office of Sponsored Projects, Technology Commercialization Office, Procurement and Supply Management, Graduate School
- other Employees whose responsibilities to the University are directly affected by the conflict of interest
Depending on the specific circumstances, the management plan approved by the Committee may also require disclosure of the conflict to human subjects participating in research, to students or other subordinates at the University, and/or disclosure of the details about your financial relationships on the University’s publicly available Conflict of Interest web-site.