Annual Conflict of Interest Disclosure / Outside Compensated Activity Approval
To: Vice Presidents and Deans
From: John V. White, Executive Vice President and Provost
Re: Approval and Disclosure Procedures for Scholarly and Professional Outside Compensated Activity/ Conflict of Interest
Date: 16 September 2013
This memorandum is to explain that this fall, we are not asking, as in years past, each professional employee to file an annual Conflict of Interest disclosure form, which has been due in years past on October 1. However, faculty members should continue to use this form, for the time being, to file updates to their outside compensated activity.
This form (.doc) along with the accompanying UNLV Conflict of Interest policy (.pdf) and Conflict of Interest Rules and Procedures (.pdf) remain available from the Provost’s and Research websites. Please be reminded that updated Conflict of Interest forms are routed from chairs/ directors to deans or vice presidents and then to the Office of Faculty, Policy and Research in the Provost’s office.
It is my hope that by introducing a separate form for securing prior approval, we will clarify that, as per NSHE Code 4.3.8 (see below), approvals are to be sought and obtained prior to undertaking outside activity, and that annual disclosure pertains to activity in the prior academic year.
The Office of Research Integrity (Research) and the Office of Faculty, Policy and Research (Provost) have been developing and vetting the new approval forms and discussing the change in time for the annual disclosure with deans, chairs and Senate executive committee since August, and they will be continuing to speak with Deans and Senate this week to get further feedback. At this time, we anticipate introducing the new approval form on November 1, with an updated version of the procedures. The updated annual disclosure survey will be conducted on Qualtrics in January.
UNLV’s Conflict of Interest procedures are governed not only by UNLV policy but also by federal regulations, state law and Regents handbook. The relevant provisions are noted in an appendix to this memorandum. Among these requirements, NSHE Handbook (Title 4, chapter 3, section 9) requires UNLV to make an annual report to the Regents of our compliance -- including number of requests for approval, number of approvals granted, number of conflicts of interest identified. Furthermore, Federal guidelines (42 CFR Part 50 and 45 CFR Part 94) require UNLV to certify that our federally funded investigators (including those who receive federal pass-through funds) do not have interests which pose a conflict with federally funded activity. Compliance is essential to ensure continued UNLV eligibility for federal funding.