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Conflict of Commitment or Interest
Conflict of Commitment or Interest
The University of Illinois Policy on Conflicts of Commitment and Interest mandates disclosure and pre-approval of income-producing outside activities for all paid academic staff members, whether part time or full time employees.
The Office of the Vice President for Academic Affairs oversees university-wide compliance with state and federal requirements. The OVPAA website provides forms, answers to frequently asked questions, and other resources relating to our annual disclosure process, the Report of Non-University Activities. At Urbana, the Vice Chancellor for Research and Innovation is responsible for the implementation of the policy.
Familial Conflict of Interest—Policies and Resources
Many apparent conflicts of interest resulting from researcher family relationships can be managed by following standard University policies. Below are links to two relevant campus policies and a sample letter that can be modified and sent to family members who serve as co-investigators or co-participants in a sponsored research project. Some cases may require additional management mechanisms or review, as in the case where human subjects are involved in the research.
Family relationships can sometimes create conflicts of interest relative to the procurement of goods and services. It is important to work with University Purchasing to seek appropriate approvals of a procurement of goods or services when there is a familial relationship between a University employee and the vendor.
- Sample letter from Department Head to co-investigators outlining management mechanisms
- Campus Policy on Employment of Relatives (Campus Administrative Manual)
- Conflicts of Interest in Supervisory Relationships (Campus Administrative Manual)
Guidance on Faculty Appointments and Conflicts of Interest
Pursuant to the University Statutes (Article IX, Section 5, c, d), full-time members of the academic staff shall fulfill the responsibilities associated with the rank and terms of their appointment. Active participation in external activities, however, can enhance professional skills and/or constitute public service that is beneficial to the university and the individual. To ensure that tenure-system faculty and other full-time academic staff members are primarily committing their time and intellectual energies to the teaching, scholarly research, service, and public engagement activities of the university, prior written approval must be obtained before engaging in non-university activities.
It is the responsibility of each full-time faculty and academic staff to ensure that external activities do not interfere with the interests of the University of Illinois. To permit the university to monitor the activity on an ongoing basis, the faculty must follow the process set forth in the Conflict of Interest and Commitment Policy (COCI).
According to the Conflicts of Commitment and Interest (COCI) Policy, “[a]cademic staff members are required to obtain prior written approval for all non-university income producing activities, to disclose promptly relationships which may give rise to a potential conflict of interest, and to respond fully and in a timely manner to inquiries from [their unit executive officer] in connection with these requests and disclosures.” The Policy explains that:
- A conflict of commitment arises when the external activities of an academic staff member are so demanding of time or attention that they interfere with the individual's responsibilities to the university.
- A conflict of interest occurs when the academic staff member is in a position to advance his or her own interests or those of a third party, to the university's detriment.
Examples of situations that potentially can create a conflict of commitment/interest include: (a) outside teaching by full-time faculty, other than that assigned or approved by the department; (b) outside consulting that takes a significant amount of time away from university responsibilities; and (c) an honorary faculty title or appointment (whether paid or unpaid) that could result in intellectual property/citations or other scholarly accomplishments of Illinois faculty being attributed to another institution. Please note that these examples are by no means exhaustive.
Faculty relationships (e.g., employment, appointments and other income producing activities) with other institutions of higher education pose particularly sensitive conflict of interest and commitment issues. All such outside activities must be disclosed and pre-approved. Please note, however, that a faculty member who accepts a tenure-track or tenured position at the University of Illinois may not hold a tenure-track or tenured position at another institution of higher education. Exceptions to this policy are extremely rare and must be approved by the unit Executive Office, the Dean, and the Provost.
Failure to obtain written permission prior to engaging in non-university activities may violate University of Illinois policy (see Policy on Conflicts of Commitment and Interest for information regarding activities requiring prior approval) and also could violate Illinois law (University Faculty Research and Consulting Act, 110 ILCS 100/1). Such violations could result in appropriate employment action.
University Faculty Research and Consulting Act (110 ILCS 100/1)
University Statutes, Article IX, Section 5, c, d)
Policy on Conflicts of Commitment and Interest (COCI)
Creating Conflict Management Plans
Letter Templates for Conflict Management
Below are templates for letters that may be useful in managing apparent conflicts of interest. Please contact the Conflict of Interest Office, 333-0034, email@example.com, if you have questions, or if you would like assistance in revising a letter.
Unit Executive Officer Confirmation of Conflict Management
This letter may be sent by a Unit Executive Officer (UEO) to acknowledge an employee’s acceptance of the Terms and Conditions for conflict management. Together, the letter to the employee and the Report of Non-University Activities may constitute a plan for the management of conflicts of interest.
Familial Conflict of Interest
This letter may be sent to family members who collaborate on research projects, or who may be paid on the same sponsored research agreement.
University Interest in Employee Consulting
This letter may be sent to an employee by the UEO to document that the University has no interest in any intellectual property developed in the course of faculty outside consulting, provided that certain conditions are met.
- Example Disclosure Language
- Licensing Intellectual Property Developed at the University of Illinois at Urbana-Champaign to Companies Affiliated with University Employees
- National Bureau of Economic Research (NBER) Guidelines
- Office of Buisness and Financial Services(OBFS) Policies and Procedures
- Office of Research Integrity, U.S. Department of Health and Human Services, Introduction to the Responsible Conduct of Research
Contact the campus Conflict of Interest Office with any questions, concerns, or for assistance: 333-0034 or firstname.lastname@example.org.