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Why do I have to complete a Conflicts of Interest disclosure form every year?

Nevada law, NSHE policy and University of Nevada, Reno policy all require an annual disclosure of potential conflicts of interest, both financial conflicts and time/effort conflicts. The policies also cover compensated outside professional services (COPS) activity (consulting).

To whom does the policy apply?

The COI policy applies to all employees of the University of Nevada, Reno, whether full time or part time. This includes academic faculty, administrative faculty, classified staff, LOAs, GRAs, Post Docs, Medical Residents, Medical students, and any other category of personnel that is paid by the University.

Why do we have a COI policy?

The Conflicts of Interest Policy protects the objectivity and integrity of the work of the University and its individual faculty and staff members. The Policy is designed to ensure that faculty and staff members identify, disclose, and appropriately manage or eliminate situations in which their personal or familial interests might otherwise compromise or appear to compromise their objectivity as teachers, researchers or administrators.  An effective conflicts of interest policy helps both to safeguard the work and reputations of University faculty and staff members and to ensure the University's compliance with federal and other regulatory requirements relating to conflicts of interest.

If I am part time do I still have to do this?

Yes, all employees, full time and part time, faculty and classified, are required to complete the annual disclosure.

I am a Graduate Assistant, Post Doc, LOA, Med Student or Resident. Do I have to complete the disclosure?

Yes. If you receive a paycheck from the University, you must complete the annual disclosure.

What conduct is of concern under the Policy?

In general, the Policy focuses on personal or familial financial interests that could bias or appear to bias an employee's work at the University. The Policy requires faculty and staff members to consider whether they have personal or familial financial interests that intersect significantly with their University responsibilities.  If so, the Policy provides a process for disclosing and dealing with the actual or potential conflict.

What financial matters have to be disclosed?

Any significant financial interest must be reported. This includes ownership by you as the Employee or Household or Family or Family Member of 5% or more of the capital stock, assets, or control of any business entity or income amounting to more than $5,000.00 aggregate in a 12 month period from a single external entity to the Employee and his/her Household or Family or Family Member or 5% or more of the gross income of the Employee or Household or Family or Family Member from any business entity. It includes anything of significant monetary value, including but not limited to salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); intellectual property rights (e.g., patents, copyrights and royalties from such rights); or other item of monetary value. Significant financial or other interest also includes the holding of a position as an officer, director, agent, consultant or Employee of a business entity. Significant Financial or other Interest includes such interests held by the Employee and by the Employee’s Household or Family or Family Members. The term does NOT include:

  1. Salary, royalty income from copy-written materials except for income derived from technology transfer licensing, or other remuneration from the University;
  2. Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
  3. Income from service on advisory committees or review panels for public or nonprofit entities;
  4. Equity interest that when aggregated for the Employee and the Employee’s Household or Family or Family Member meets both of the following tests:
  • Does not exceed $5,000 in value as determined through reference to public prices or other reasonable measure of fair market value, and
  • Does not represent more than a five percent (5%) ownership interest in any single entity.

Do I have to report book royalties?

No. Royalties you are paid from book sales are specifically excluded from reporting requirements.

Do I have to report review panel honoraria?

No. Serving on a review panel is considered service and honoraria you receive or expenses paid as a result of that service are not reportable.

Who would be considered my Family or Household members?

Family member is defined in the policy as your spouse and any other persons such a child, parent, sibling or other family member claimed on your (the Employee’s) tax return. Household members means an association of persons who live in the same home or dwelling, sharing its expenses, and who are related by blood, adoption or marriage.

Is there a monetary threshold below which I do not have to report other income?

Yes. Income received from sources other than your University salary, which in aggregate is less than $5,000 for the year need not be reported.

Do I still need permission to consult if my consulting income is less than $5,000 annually?

Yes, if you are full time faculty, all consulting activity requires prior permission. If you are part time faculty, you do not need permission to engage in COPS activities.

Why do I have to get prior approval for consulting?

NSHE and UNR policy both require all full time faculty to seek approval for any COPS activity prior to beginning the consulting work.  The COPS form must be submitted to your dean, director, or supervisor on an annual basis for as long as the consulting activity occurs. Your dean, director or supervisor must respond to your request within 10 days. Rules for administrative and academic faculty are different so we suggest you consult the conflict of interest policy for details.

I am not familiar with the form used to get permission to consult. Is the COPS form new?

Yes, both the form and formal policy were developed in 2011.  The form is now being used for all faculty consulting activity.

Why do you have to collect so much detail on disclosed activities?

COI/COPS activities are reported to the NSHE Board of Regents every year. The information provided on the annual disclosures provides the information required by the Regents and is reported in the aggregate only. No names or individual details are included in the reports.

What happens to the information I provide on the disclosure form?

All disclosure forms are considered personnel files and are therefore private and available only to authorized individuals, such as the COI Committee, your dean, chair, vice president or human resources staff. The forms are maintained in a secure, electronic environment and are printed only for review by the COI Committee or other authorized individuals.

Who determines what is a conflict of interest?

The Conflicts of Interest Committee is charged with making the determination of any actual conflict of interest. After the disclosure forms are submitted, the committee reviews any that have answers indicating a potential conflict.

What happens if the COI Committee thinks I have a Conflict of Interest?

You will be contacted by the Designated Official for Conflicts of Interest. S/he may ask for additional information or that you meet with the committee. Often, the additional information is all that is needed. In the event you are invited to meet with the committee, you will be encouraged to bring any necessary documentation to help the Committee make a determination.

If the Committee does determine that a conflict exists, what happens then?

The Committee will work with you to craft a suitable Management Plan (MP) to manage the conflict in such a way that both you and the university are protected. Any MP must be signed by the Committee, your dean, a university administrator charged with monitoring the MP, and the University President. Regular reporting is required.

Whom do I contact if I have questions?

Contact Nancy Moody, Director of the Research Integrity Office and the Designated Official for Conflicts of Interest, or (775) 327-2368.

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