Conflict of Interest – Annual Reminder

Submitted on Tue, 06/02/2020 - 11:19 am

Coordinated message from Edward Nasser, Chief Procurement Officer, Procurement and Contracting Services
and Taren Ellis Langford, Director, Conflict of Interest Office

The University of Arizona ("the University") has conflict of interest-related policies that may be applicable to you.  Below, we would like to remind you of your obligations under four of those policies – PACS Conflict of Interest Policy, the Individual Conflict of Interest in Research Policy, the Conflict of Commitment Policy, and the Institutional Conflict of Interest Policy.

1.  PACS Conflict of Interest Policy

The purpose of the Conflict of Interest statutes is to remove or limit the possibility of personal
influence that might bear upon a University employee's decision in his or her capacity as a public employee. Accordingly, the Arizona Revised Statute (A.R.S. 38-501 et seq.) requires an employee who has, or whose relative has a substantial interest in any contract, sale, purchase, or service by or to the Board of Regents or the universities, as well as in any decision, to disclose said interest in the official records of the Board. Such disclosures for University employees and their relatives are submitted through the Procurement and Contracting Services (PACS) office for review and conflict determination.

If such an interest exists, the employee shall refrain from participating in the decision, contract, sale, or purchase in any manner.

Conflicts of interest can arise naturally from an individual's engagement with the world outside the University, and the mere existence of a conflict of interest does not necessarily imply wrong doing on anyone's part. When conflicts of interest do arise, however, they must be recognized, disclosed and either eliminated or properly managed.

Please refer to University Purchasing Policy #1.4 – Conflict of Interest, for more detailed information and the procedures for disclosing a substantial interest.

Please note that completion of the PACS conflict of interest disclosure does not take the place of any additional disclosure requirements to comply with other Federal, State or University conflict of interest requirements, including those listed below. For information regarding additional disclosure requirements please visit the University's COI Program website.

*There is no need to submit a disclosure form to PACS if no conflicts exist. (This is different than your research disclosure described below).

**If a Conflict of Interest has already been disclosed and a decision has been rendered by PACS, there is no need to re-submit the same disclosure unless there's been a change since the initial submittal.

2.  Individual Conflict of Interest in Research Policy

All Investigators are required to disclose their significant financial and personal interests and their sponsored and non-sponsored research projects to the COI Office. An Investigator is “any person who is responsible for the design, conduct or reporting of Research.” This includes all persons who are responsible for the design, conduct or reporting of Research regardless of their title, employment status and percentage of effort. While this may include students, trainees, collaborators, volunteers and consultants if those individuals have some degree of independence in performing some aspect of the design, conduct or reporting of the Research, it does not include individuals whose performance is purely ancillary or occurs solely under immediate supervision.

Investigators are required to do the following:

  1. Training: Complete the Conflict of Interest Required Disclosure Training once every four (4) years or more frequently as directed by the COI Office.
  2. Outside Interests: Submit a COI disclosure listing their Significant Financial Interests and Significant Personal Interests as those terms are defined in the University's Individual Conflict of Interest in Research Policy. (Any payment, reimbursement, travel support or other compensation, of any amount, that an Investigator has personally received, or will personally receive, from a foreign entity should be disclosed as an Outside Interest in their COI disclosure.) If an Investigator does not have any Outside Interests, they must submit a COI disclosure certifying that they do not have any such interests. COI disclosures should be submitted using the University's electronic COI Disclosure System.
  3. Research Projects: Submit a project questionnaire for each non-sponsored and sponsored research project, if they have disclosed an Outside Interest. If a research project/protocol has not been automatically linked to an Investigator's disclosure, he or she must manually add that research project/protocol to their COI disclosure.
  4. Recertify: Recertify their COI disclosure (1) when they acquire a new Outside Interest, (2) when there are changes to a disclosed Outside Interest, and (3) annually between June 1 and June 30.

If you have any questions, please contact the Conflict of Interest Office at coi@arizona.edu or by phone at 520-626-6406.

3.  Conflict of Commitment Policy

The University's Conflict of Commitment Policy requires full-time (0.50 FTE or greater) University Staff to request approval for any Outside Professional Commitments or Outside Employment.  Approval should be sought from your supervisor or, in the case of faculty, from your department head and dean by submitting an electronic Conflict of Commitment Form.

  • Any payment, reimbursement, travel support or other compensation, of any amount, that an individual has personally received, or will personally receive, from a foreign entity must be disclosed as an Outside Interest in their COI Disclosure. Investigators should carefully follow the new and evolving guidelines from federal agencies regarding the identification of all sources of research support.

If you have any questions, please contact the Conflict of Interest Office at coi@arizona.edu or by phone at 520-626-6406.

4.  Institutional Conflict of Interest Policy

All University Administrators are required to disclose their financial interests to the COI Office.  A University Administrator is any individual in a position of administrative leadership of a recognized University college, academic department, business, or other administrative unit, where a regular job requirement is to make institutional decisions on behalf of the University of Arizona. The role of a University Administrator includes, but is not limited to, the following positions (whether such positions are staffed on an interim, full-time, or part-time basis):

  • University Vice/Associate/Assistant Presidents
  • University Provost and Vice/Associate/Assistant Provosts
  • University Deans and Vice/Associate/Assistant Deans
  • University Directors
  • University Department Heads/Chairs
  • University Business Officers/Managers
  • University Division Chiefs, Center Heads/Directors
  • University employees with the authority to sign agreements on behalf of the University of Arizona
  • Individuals who serve as Chairs on the University's Institutional Review Board committees, regardless of whether such individuals are employees of the University

University Administrators must disclose their Significant Financial Interests at the time of initial appointment, and thereafter annually during the month of reappointment, and within thirty (30) days of the existence of any new Significant Financial Interest.  (Significant Financial Interest is defined in the University's Institutional Conflict of Interest Policy.) These disclosures should be submitted using the University's electronic COI Disclosure System.

If you have any questions, please contact the Conflict of Interest Office at coi@arizona.edu or by phone at 520-626-6406.