Conflicts of interest

The University encourages and supports interactions of its faculty, staff and students with federal, state, and local governments, and with business and industry as important opportunities for research, education, and public service.

The University also recognizes that outside activities or interests can lead to real or perceived conflicts of interests (COI). Conflicts of interests arise when financial or other personal considerations have the potential to adversely affect, or have the appearance of adversely affecting, an employee’s professional judgment or to fulfill his or her obligations to the University. Unmanaged conflicts of interest can call into question the professional objectivity and ethics of the individual, and reflect negatively on the University.

Education, research, hiring decisions, procurement and all other University activities must be free from the undue influence of outside interests. All University employees are considered public employees and must comply with the Code of Ethical Standards of the State of Nevada as codified in NRS 281 A.400 - 281 A.660.

It is important to note that conflicts of interests do not imply wrongdoing; they are practically inevitable at a research university. Activities can usually continue with proper oversight and safeguards. The most effective way to ensure transparency and oversight of conflicts of interest is through disclosure, review, and management.

Disclosure of potential conflicts of interests

Disclosure is the key to successfully managing conflicts of interests. Per University policy, all University employees are required to submit an online conflict of interest disclosure if they have any of the significant financial interests and/or external relationships listed below (1) at the time of hire and (2) within thirty days of discovering or acquiring a new significant financial interest or external relationship.

Additionally, the following employees must annually submit a conflict of interest disclosure during the University’s conflict of interest campaign.

• Academic faculty
• Administrative faculty
• Classified staff
• Medical residents
• Postdoctoral Fellows

During the annual COI disclosure campaign, these employees either identify actual or potential conflicts of interests, or provide an attestation that none exist.

What needs to be disclosed?

• Financial interests
• External relationships
• Paid travel – if you are an Investigator or Key Personnel on a project sponsored by a Public Health Service agency, such as the NIH
• Situations that could negatively impact students and trainees

Another type of potential conflict is a conflict of commitment. Before participating in a compensated outside scholarly or professional activity, full-time University faculty and classified employees are required to provide notification and request approval from their supervisor.

• Compensated Outside Activities (COA) that require prior notification and approval

The disclosure of possible conflicts of interests/attestation of none and the prior notification/approval of compensated outside professional activities are accomplished online through InfoEd.

Review

Potential conflicts of interests will be reviewed by the University's COI Designated Official and possibly the COI Committee. Requests to participate in compensated outside scholarly or professional activities will be reviewed by the employee’s supervisor or designee. If the supervisor/designee is concerned about possible conflicts of interests, the request may be forwarded to the COI Designated Official for further review.

Management

If the COI Committee determines that an actual or perceived conflict of interests exists, the COI Designated Official will work with the employee on the development of a Management Plan. The Management Plan articulates the steps that will be taken to mitigate the risk of impaired objectivity. In rare situations, the COI Committee may determine that the conflict cannot be managed and the factors resulting in the conflict need to be eliminated.

COI Training

Investigators on projects sponsored by the Public Health Service (NIH, CDC, SAMHSA, CMM, etc.), agencies that have adopted Public Health Service COI policies, the Department of Energy and others require that all persons who meet the criteria of “investigator” complete COI training prior to expenditure of any grant funds and at least every four years thereafter. Additionally, everyone covered by a COI Management Plan must complete COI training. Others may be required to complete COI training as needed. The University utilizes the online COI training through CITI to meet these requirements.

Non-compliance with COI policy

Violation of the UAM 2,050: Conflict of Interest Policy may result in discipline as specified under NSHE Code Chapter 6 and UAM 2,370 and could result in civil and criminal penalties pursuant to NRS chapter 281 A.500-550.

Compliance with this policy may be enforced through the exercise of administrative responsibility for oversight of funded research and management of University facilities and other University property. Such measures include, but are not limited to:

• Freezing research funds or accounts
• Rescinding contracts entered in violation of this policy or Federal or state law
• Bringing legal action to recover the amount of financial benefit received by an employee as a result of the employee's violation of this policy

Learn how to safely navigate through COI policies.

For more information

For more information about conflicts of interest or conflicts of commitment, please contact the University's COI Designated Official, Michele Dondanville at (775) 784-6360 or mdondanville@unr.edu.

Information about reporting suspicions of improper activity.