All faculty and staff, including student employees, as well as their Unit Heads and others covered under the UAH Institutional Conflicts of Interest and Conflicts of Commitment Policy (06.09.05), should evaluate and appropriately arrange their external and internal interests in order to avoid compromising their ability to carry out their primary obligations to the University. The policy also requires UAH employees to review and recertify disclosures of Conflicts of Interests (COIs) and Conflict of Commitments (COCs) annually.

All UAH employees are required to complete an institutional COI and COC disclosure form:

  • within 30 days of hire, transfer, or promotion;
  • within 30 days of an actual or potential COI or COC being identified; and
  • annually thereafter.

All UAH employees are required to complete annual Avoiding Conflicts of Interest training:

  • within 30 days of hire; and
  • annually thereafter.

Institutional COI/COC Program Workflow

New Employees

  • Within 30 Days of Hire

All Employees

  • Annually
  • Within 30 Days of an Actual or Potential COI/COC Being Identified
  • Within 30 Days of Transfer or Promotion
  1. Complete the Online Training
  2. Complete the Disclosure Form
    1. If COI/COC is identified, Chief Risk & Compliance Officer (CRCO) notifies appropriate Unit Head.
    2. Employee & Unit Head create Management Plan and submit it to CRCO
    3. ICIRB reviews Management Plan and submits recommendations to Provost or VPA
    4. Provost or VPA approved Management Plan or returns Management Plan to ICIRB with comments
      • ICIRB reviews comments and returns Management Plan to Unit Head for revision.
      • Unit Head develops and resubmits revised Management Plan to ICIRB within 30 days.
  3. Update Approved Management Plan (if applicable)

Learn More

FAQs

  • All new employees must complete the Disclosure Form within thirty (30) days of hire.
  • All employees with an actual or potential COI or COC must complete the Disclosure Form within thirty (30) days of the time the COI or COC is identified.
  • Any employee with an identified actual or potential COI or COC must complete an updated disclosure form annually, regardless of whether an Approved Management Plan is in place, until such time as the COI or COC no longer exists.
  • Any employees must complete the Disclosure Form upon transfer or promotion to a new position within the University.

Visit Kuali Build to access the disclosure form. Please utilize your UAH Charger ID credentials to access the form via UAH Single-Sign-On (SSO). Instructions are provided at the top of the disclosure form.

All Disclosure Forms are to be submitted to the Office of Risk Management and Compliance and will be reviewed by the Chief Risk and Compliance Officer (“CRCO”). If a COI/COC is identified, the CRCO will notify the appropriate Unit Head in writing with details of the COI/COC. This notification will state that a Conflict Management Plan should be developed in accordance with Policy 06.09.05.

If you’re having trouble signing into United Educators utilizing your UAH credentials through Single-Sign-On (SSO), please reach out to the HelpDesk at 256.824.3333 or helpdesk@uah.edu.

If you’ve been able to sign into United Educators but are not able to find the course module, use the search feature to find and complete the course. Enter "Conflicts" into the search bar at the top of the screen that reads "search content in the platform", and click the magnifying glass icon. The "Avoiding Conflicts of Interest" course module should populate.

If you are still unable to find the course module using the search feature, please reach out to compliance@uah.edu or 256.824.6396.

No, you do not need to submit your training certificate after completing the course. ORMC staff have access to records to verify your successful completion of the course.

We do encourage you to download and save a copy of your certificate for your records.

Definitions

A Management Plan, as defined in this Policy, that has been approved by the Provost and Executive Vice President (“Provost”) (for faculty COI/COC) or the Vice President for Finance and Administration (“VPFA”) (non-faculty COI/COC). An Approved Management Plan is valid for one (1) year and must be renewed annually for so long as the identified COI/COC exists.

A plan that describes an actual, potential, or perceived COI/COC in detail, and outlines measures to actively reduce, mitigate, or eliminate the COI/COC. The Unit Head and the responsible Employee work together to develop a Management Plan. Management Plans must be signed by the Unit Head and the responsible employee. Management Plans are forwarded to the Institutional Conflict of Interest Review Board for review, comment, and recommendation. Management Plans do not become Approved Management Plans until approved by the Provost or the VPFA as appropriate to the employee classification (refer to the definition of Approved Management Plan).

A Conflict of Commitment refers to a situation where an individual engages in external or internal activities, either paid or unpaid, that interfere with their Institutional Responsibilities and time commitment to the University.

A Conflict of Interest refers to a situation in which an individual’s financial, professional, or other personal considerations may directly or indirectly affect, or have the appearance of affecting, an individual’s professional judgment in exercising any University duty or responsibility. Typically, a Conflict of Interest may arise when an individual has the opportunity or appears to have the opportunity to influence the University’s business, administrative, academic, clinical, research, or other decisions in ways that could lead to improper financial, professional, or personal benefit or advantage of any kind, whether or not the value is readily ascertainable.

Any faculty member, staff member, student employee, or contracted worker, whether full- or part-time, and whether permanent, temporary, or on-call. Generally speaking, any individual earning W-2 reportable wages from UAH would be classified as an employee for the purposes of this Policy.

An activity not included within ones’ University employment responsibilities and performed for an entity other than UAH, whether or not for compensation, that draws on the professional knowledge, skill, and/or talents that employees utilize to fulfill their Institutional Responsibilities at UAH, including but not limited to the following:

  • external employment;
  • consulting;
  • lecturing, presenting, performing, or speaking;
  • establishing and/or supporting a start-up company;
  • serving as an expert witness;
  • serving on a board of directors or similar governing body;
  • serving on a scientific advisory board, or
  • appointments or other commitments to other academic institutions or research institutes.

Professional activities or affiliations traditionally undertaken by faculty outside of the immediate institution employment context but where the faculty member represents UAH. Faculty Secondary Responsibilities may or may not entail the receipt of honoraria, remuneration, or the reimbursement of expenses, and may or may not include Professional Public Service Activities. Faculty Secondary Responsibilities are a subset of Institutional Responsibilities.

All activities, duties, and responsibilities performed by an employee of UAH in the course of their primary employment or other relationship with UAH, including, but not limited to: scholarship, research, consultation, teaching, professional practice, administration, contracting or procurement responsibilities, Faculty Secondary Responsibilities, or Professional Public Service Activities undertaken in the course and scope of UAH employment.

Activities performed for or on behalf of UAH by a UAH employee. Internal Activities may include, but are not limited to, Institutional Responsibilities as defined herein, non-instructional activities performed for additional compensation, volunteer activities, consulting/advising another UAH department/unit, providing instructional services for additional compensation, and service on committees/boards/etc.

Activities specifically enumerated below for the groups specifically enumerated below, when such are considered part of an employee’s Institutional Responsibilities, whether or not separately compensated:

  • professional studies (e.g., attendance at scientific meetings);
  • seminars, lectures, performances, presentation, or continuing education sessions;
  • service on review panels (e.g., participation in manuscript review, grant/contract review, academic program review, etc.);
  • service on advisory committees; or
  • service on a board of directors or similar governing body

provided to:

  • U.S. federal, state, or local government agencies;
  • institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education, whether U.S. or abroad;
  • lecturing, presenting, performing, or speaking;
  • nonprofit/philanthropic entities, professional societies, or professional associations that are not affiliates of or affiliated with industry or other for-profit entities;
  • organizations accredited or approved by the appropriate independent boards or bodies governing oversight of continuing professional education activities; or
  • civic groups.

Thresholds (i.e., types and amounts) of financial interest of employees or their spouse or dependents that reasonably appear to be related to the employee’s Institutional Responsibilities as set forth below:

  • With regard to any publicly-traded entity, SFI exists if the value of the financial interest received from the entity in the current or prior calendar year exceeds $1,000 in the aggregate.
  • With regard to any non-publicly traded entity, a SFI exists if:
    • the value of any remuneration received from the entity in the current or prior calendar year exceeds $1,000 in the aggregate; or
    • the employee or a spouse or dependent(s) holds any equity interest (e.g., stock, stock option, or other ownership interest).
  • With regard to intellectual property rights and interests (including but not limited to patents and copyrights), a SFI exists for any intellectual property licensed, optioned, or that has generated income/revenue.
  • SFI does not generally include remuneration for Professional Public Service Activity with U.S. entities, textbook royalties, peer reviewed journal editorship activities for publishing companies, or other related items as determined by the Institutional Conflict of Interest Review Board.

Cognizant dean, chair, director, officer, associate or assistant vice president, vice president, or president, who has executive management responsibilities for supervising a department, unit, center, college, or division.