Conflicts of Interest
All UNI employees must be able to act and make decisions that are free from bias engendered by unmanaged conflicts of interest and commitment, and to foster integrity and transparency in academic and business activities. While faculty, staff, and administrators are encouraged to develop external activities and relationships, they must maintain those in a way that does not adversely affect their duties and obligations to the university. University policy requires that employees disclose any potential conflicts of interest or commitment that may arise and work with the UNI Conflict of Interest Officer (COIO) to manage or resolve them.
Conflicts of Interest & Commitment
The University of Northern Iowa requires the disclosure, review/approval, and management of external activities or financial interests with the potential to interfere with one or more of the following:
- Performance of Duties: Individuals are expected to devote sufficient time and attention to their university duties to perform them conscientiously. An external activity with the potential to interfere with the employee's university duties is known as a conflict of commitment.
- Objectivity: Individuals are expected to be objective in the decisions they make while performing their university responsibilities. Financial or other personal considerations with the potential to compromise an employee's objectivity are known as conflicts of interest.
- Appropriate Use of State Resources: State law prohibits the use of state resources, including the university name and trademarks, for personal benefit when such use is detrimental to the state or university. An individual’s relationship with, equity interest in, or management role within a non-university entity does not necessarily constitute a conflict of interest. A conflict may arise, however, when such relationships interfere or compete with one another or with an employee's relationship to the university. Conflicts are sometimes unavoidable in professional activities; the key to integrity is in managing them appropriately.
Conflicts in Project involving External Funding
For individuals applying for or involved in projects that are funded by the Public Health Service, please consult the Policy on Conflicts of Interest Involving Research Funded by the Public Health (PDF) Service and use the UNI PHS External Interests Reporting form (PDF) within the required time frames. All key personnel on PHS projects must submit this form prior to submitting a grant application to a PHS agency, update it upon award if necessary, and then annually thereafter. Training in conflicts of interest will also be required of all key personnel within 60 days of award and every 4 years thereafter.
For individuals applying for or involved in National Science Foundation or other externally funded projects, please consult the policy on Management of Conflicts of Interest in Projects with External Funding and use the form embedded in that policy if/when a disclosure is required by the policy.
If you are not sure how to proceed or otherwise have questions about the policies and documents, contact the RSP Conflict of Interest Officer Tolif Hunt. He is also the one to whom all disclosure forms should be submitted at 213 East Bartlett Hall, mail code 0394.
CITI Training in Conflicts of Interest
Key personnel involved in PHS-funded projects are required to obtain training in the PHS regulations on conflicts of interest, which can be accomplished by completing a tutorial offered by the Collaborative Institutional Training Initiative (CITI) program. UNI subscribes to this program for courses in Human Subjects, Animal Subjects, Export Controls, and the Responsible Conduct of Research, as well as Conflicts of Interest. Some of the information in these programs overlap so be sure to take the course that meets the requirement you are addressing. It may be helpful to review the instructions for accessing the CITI program before beginning a course. Upon completion, a certificate may be printed as documentation – the certificate will also be automatically emailed to RSP.
Sponsors Using PHS RCOI Regulations
NIH: All Institutes and Centers of the National Institutes of Health
Other DHHS Funding Agencies:
- AFC: Administration for Children and Families
AoA: Administration on Aging
AHRQ: Agency for Healthcare Research and Quality
ATSDR: Agency for Toxic Substances and Disease Registry (Part of CDC)
CDC: Centers for Disease Control and Prevention
CMS: Center for Medicare & Medicaid Services
FDA: Food and Drug Administration
HRSA: Health Resources and Services Administration
IHS: Indian Health Service
SAMSHA: Substance Abuse and Mental Health Services Administration
BARDA: Biomedical Advanced Research and Development Authority