Reviewing Conflict of Interest and Conflict of Time and Commitment Disclosures
1. The first role is evaluative. The department head should review all relevant information. When presented with the facts of a given situation, the reviewer must first determine if there is legitimate cause for concern related to the inappropriateness of behavior or evidence of bias by the professional activities of the staff member.
The following questions are suggested for this initial determination.
- Has all the relevant information concerning the staff member's activities been acquired (i.e., has there been full disclosure)?
- Do the staff member's relevant financial interests suggest the potential for conflicts or the appearance of conflicts or bias?
- Do the staff member's reported external time commitments exceed permissible levels?
- Is there any indication that the staff member in his or her professional role has improperly favored any outside entity or appears to have incentive to do so?
- Has the staff member inappropriately represented the University to outside entities?
- Does the staff member appear to be subject to incentives that might lead to conflicts or bias?
- Is there any indication that obligations to the University are not being met?
- Is the staff member involved in a situation that might raise questions of bias, inappropriate use of University assets, or other impropriety?
- Could the staff member's circumstances represent any possible violation of federal or state requirements?
- Do the current engagements of the staff member represent potential conflicts between outside interests (e.g. working on projects simultaneously for competing business entities?)
- Could the proposed activity withstand public scrutiny?
2. After appropriate evaluation, most situations will be found to be;
- Permissible since the disclosed information does not represent a possible source of bias or an inappropriate activity;
- Permissible with modifications aimed at avoiding bias or inappropriate activities; or
- Inconsistent with University policy and this not permissible.
3. In a case where faculty activity is permitted but requires modifications. Options are as numerous as the types of situations the committee may review. Possible options include, but are not limited to:
- public disclosure of all relevant information;
- reformulation of the research work plan;
- close monitoring of the research project;
- divestiture of relevant personal interests;
- termination or reduction of involvement in the relevant research project;
- termination of inappropriate student involvement in projects;
- severance of outside relationships that pose conflicts; and
- reimbursement by the staff member to the University for indirect costs and for the use of laboratories, equipment, facilities and other resources.