CONFLICTS OF INTEREST REPORTING AND APPROVAL PROCESS

A new policy related to conflicts of interest or commitment became effective January 1, 2008, Faculty Staff Handbook 6240. The purpose of the policy is to ensure that employees devote their primary professional time and energy to the university and to the mission of teaching, research and public service. Outside activities and financial interests are to be reported on an annual basis in accordance with the policy and must be arranged so as not to interfere with the primacy of these university duties.

Step 1: Initial disclosure: to be completed by all employees

All employees are required to complete and submit a Disclosure of Potential Conflicts of Interest and Commitment on an annual basis, whether or not the employee has any situation that presents an actual or potential conflict to disclose. (See FSH 6240 D-1 .) The disclosure form shall be included with the performance evaluation. Please note if your evaluation form for the 2008 cycle does not include a disclosure statement at the bottom, you may obtain a disclosure statement here: http://www.webs.uidaho.edu/fsh/6240.html or at the link below. Beginning with the 2009 evaluation cycle all evaluation forms will include the disclosure form. The employee and supervisor are to discuss situations that may be considered conflicts of interest or commitment using section C of FSH 6240 as guidance. If no actual or potential conflicts are present, the disclosure form is marked accordingly and no further action is required until the next performance evaluation cycle or the employee’s situation changes and an actual or potential conflict arises.

Step 2: Detailed disclosure and development of a management plan: to be completed only employees with a conflict to disclose

If the employee or the employee and supervisor believe an actual or potential conflict exists, to the employee will need to complete form FSH 6240A Disclousure of Conflicts and submit a description of the situation and proposed Management Plan, using the management plan questionnaire and template. Once Form FSH 6240A, the questionnaire, and the management plan are completed, including obtaining the required signatures on FSH 6240A, the employee shall submit package to the Committee on Ethical Guidance and Oversight for review. The submission should be in electronic form sent to ethics@uidaho.edu.  Individuals are encouraged to seek assistance from their supervisor, prior to submission of the forms and management plan if they have any questions.  Questions about the process should be directed to the Committee Chair.

The activity described in a proposed management plan submitted to the Committee may not begin until the management plan is approved by the Committee.

Step 3: Review by Committee Ethical Guidance and Oversight

Based on the submission and any follow-up by the Committee, the Committee will determine whether the proposed management plan is adequate or needs to be modified in order to adequately manage the conflict, or whether the nature of the conflict is such that it is not allowable. Their determination will be reported to the employee and his/her supervisor. Should the Committee determine that the conflicting activity is not allowable, the employee must agree in writing to stop the conflicting actions.

Step 4: Recommendation by Committee and Final Decision

Once the Committee has completed its review, it will make a recommendation regarding approval to the President or the President’s designee.

Step 5: Annual Review, Updates, Changes to Management Plans

Employees with conflict of interest management plans shall repeat steps 1-5 annually. As part of each subsequent performance evaluation, while the management plan is in place, the employee and their supervisor are to review the plan and performance under the plan. Results of the review, including but not limited to compliance with and effectiveness of the management plan, as well are any recommended changes to the plan are to be included in the submission to the Committee.

Step 6: End of Activity under a Management Plan

When the activity that is the subject of the management plan ceases, the employee must inform the Committee within 30 days of the change by submitting an updated Form FSH 6240A and the management plan will be terminated.