The following COCI procedures apply to the University of Illinois Urbana-Champaign and the University of Illinois Springfield and the system offices. Procedures for the University of Illinois Chicago can be found here. 

I. Procedures

University of Illinois Urbana-Champaign, University of Illinois Springfield and the system offices will conduct a coordinated annual disclosure and review process for conflicts of commitment and interest among its covered individuals to meet the requirements of law and of research sponsors. These processes will be conducted through the University’s online reporting tool, START myDisclosures, using the Report of Non-University Activities (RNUA). 

For the purposes of START myDisclosures and the RNUA, Non-University Activities are equivalent to Outside Activities as defined by the University’s Policy on Outside Activities and Conflicts of Commitment and Interest. See START myDisclosures.

A. Covered Individual Responsibilities 

i. Covered Individuals have the duty to request and obtain approval from their UEOs prior to engaging in activities or relationships that present actual or reasonably perceived conflicts of commitment or interest with their University responsibilities. These activities and relationships include:

Any financial interest, appointment, affiliation, entrepreneurial activity, employment, fiduciary role in an association, or Sponsored or Reimbursed Travel of the Covered Individual with an entity other than the University that reasonably appears related to or competes with the Covered Individual’s University Responsibilities or the University’s mission of education, research, public service and economic development, regardless of compensation or level of financial interest. Outside Activities may be, but are not necessarily, formalized through a written agreement.

See Examples of Allowable Outside Activities Generally Not Requiring Prior Approval or Reporting

ii. Covered Individuals will complete or update the RNUA, even if no activities are reported:

a. Upon the start date of a new hire or within 30 days of the start of a new hire University appointment; 

b. when requesting approval from the UEO for a new Outside Activity; 

c. when a change in Outside Activity occurs; 

d. when required by granting agency; and 

e. annually during the coordinated disclosure process.

iii. When requesting approval for an activity and completing or updating the annual disclosure, the Covered Individual will describe:

a. the time commitment to the activity or relationship; 

• Covered Individuals whose University appointments are less than 50% FTE are required to disclose their Outside Activities, but are not required to report the time commitment for those activities.

b. the role of the Covered Individual with the entity, if any;

c. whether the entity, if any, did/does business with the University;

d. whether any other University of Illinois faculty, staff, or students were/are involved in the activity or relationship; and

e. whether any University resources were/are used by the entity.

Conflicts of interest can arise from a Covered Individuals’ Outside Activities that occur outside their university appointment periods. Covered Individuals must report activities even if the activities are conducted outside of the University contract period. When the activities occur outside of the University contract period, the Covered Individual is not required to report or request time. 

iv. Temporary Releases from Reporting Outside Activities During the Annual Disclosure Process

a. In cases where a Covered Individual is unable to complete the annual RNUA due to medical leave or a University-approved unpaid leave, the UEO may grant a temporary release to the Covered Individual. The release exempts the Covered Individual from completing the RNUA disclosure until their return to work. 

b. If granted a temporary release from the RNUA disclosure, the Covered Individual must comply with the applicable University leave policies. If the Covered Individual engages in income-producing activities that had not been approved under the leave and/or if changes to Outside Activities occur during the leave, he or she must complete the RNUA to disclose the Outside Activities at the time that the previously unapproved activity is initiated.

c. A UEO may not grant a temporary release to a Covered Individual from reporting if they continue to conduct, administer, or applies for a sponsored project while on leave.

d. The UEO must ensure that any Covered Individual who is excused from reporting completes the RNUA upon return to work.

e. The UEO can revoke the release at any time.

See START myDisclosures Users’ Guide.

B. Reviewer Responsibilities

i. Unit Executive Officer (UEO) Responsibilities

The UEO has the primary responsibility to enforce the Policy, and that responsibility may not be delegated. The UEO or Covered Individual may seek, at any time, the advice of the dean, director, responsible official, or other individual responsible for the process that generated the disclosure. The UEO will work with the Covered Individual to identify, evaluate, and either manage or eliminate actual or perceived conflicts prior to forwarding the RNUA for the next administrative level for a second level review. 

a. The UEO has the duty to:

• Evaluate all potential conflict situations reported or known to them (including all requests for approval of Outside Activities) before approving the activities;

• Obtain sufficient information to make informed decisions under this Policy;

• Determine whether the application or use of University time or resources, if requested, is beneficial to the University’s mission. If the UEO reviewing the disclosure is not custodian of the resources, then the UEO must document the approval or agreement from the appropriate office that oversees the resources;

• When an actual or perceived conflict is identified, and a decision is made to allow the activity to proceed, develop an appropriate management plan with the Covered Individual that specifies the review timeline;

• Implement management plans for activities that present actual or perceived conflicts of commitment or interest;

• When an actual or perceived conflict is identified and a management plan is implemented, route the disclosure and management plan for a second level of review;

• Using START myDisclosures, notify Covered Individuals within 14 days of the decision on a request for approval of the submitted RNUA; 

• Monitor Outside Activities of Covered Individuals and oversee and regularly evaluate/update management plans; and

• Notify appropriate University offices if the actual or perceived conflict results in a performance issue, misuse of University resources, or a violation of University policies and/or procedures.

b. Multiple Unit Executive Officers

• When a Covered Individual holds paid appointments in multiple units, the UEO of each unit must review and approve the Covered Individual’s disclosures and requests for prior approval of Outside Activities. The UEO of the Covered Individual’s home unit takes the lead in this process. When a second level of review is required, it follows the regular reporting line based on the home unit.

• If a UEO does not approve the proposed activities or the management plan, a second level of review must occur, and the decision on second-level review will be final, subject only to appeal on procedural grounds.

• UEOs of units in which Covered Individuals hold “courtesy” appointments will have access to the RNUAs of those appointees but will not approve or deny Outside Activities.

c. Revoking Approval

• If at any time, the UEO perceives that the conflict management plan mechanisms are no longer effective, the UEO must revoke approval of the Outside Activity and work with the Covered Individual to evaluate the situation and revise the management plan. 

• The UEO of the home department shall inform the UEO at the second level when a management plan has been revoked.

ii. Second Level of Review

A second level of review is required for any Outside Activities presenting an actual or perceived conflict of commitment or interest. The review takes place at the next administrative level above the Covered Individual’s home department. For example, the dean of a college completes the second level of review when a department head determines an actual or reasonably perceived conflict of commitment or interest exists.

a. The administrator at the second level of review has the duty to: 

• Review the proposed activities and management plan;

• Request additional information, as needed, prior to approving the management plan; and

• Work with the Covered Individual and first level UEO to finalize a management plan.

b. The second level of review is not an appeal but is a routine part of the process. The administrator at the second level review is required to work with the administrators at the first level review when the second level reviewer has concerns about the activities reported, the first level reviewer’s assessment of the conflict of interest or commitment, and/or the proposed management plan.

iii. Responsible Official

As the individual responsible for overseeing the implementation of the Policy, the Responsible Official has the duty to:

a. Oversee and approve management plans prior to execution of licensing agreement for intellectual property and technology owned by the University;

b. In cases of non-compliance, enforce compliance with the University policy;

c. When activities are denied by the second level of review, serve as the arbiter of the appeal and make final determination on the review;

d. Ensure that any requirements for reporting of significant financial interests or conflicts of interest imposed by laws, regulations or contracts are met;

e. Report to external agencies, when required by law or contract;

f. Provide external agencies access to relevant documents for investigations or audits, when required by law or contract; and

g. Comply with public disclosure requirements of external agencies, when required by law or contract.

C. Conflict Management Plans

Conflict management involves the completion of an annual disclosure and approval process; and may require the execution of a written conflict management plan.

See RNUA Terms and Conditions

i. Conflict management plans must implement mechanisms and oversight to address, at minimum, the following:

a. Time spent on the Outside Activities;

b. The potential involvement of students and/or other University employees in the activities;

c. The potential use of University intellectual property or any other use of University resources;

d. The relationship of an Outside Activity to a Covered Individual’s University duties or responsibilities; and

e. The potential for diversion of funding opportunities to an outside entity.

ii. Conflict management plans must be reviewed and approved by the UEO and the administrator at the second level of review.

See Activities that Require Management.

D. Recusal and Confidentiality

Any UEO or administrator at second level of review involved in negotiating or administering conflict management plans must disclose in writing to the next administrative level any actual or perceived conflict that they have in the matter. If such a conflict is disclosed, the conflicted party may not participate further in the process, and the responsibility for conflict management then passes to the next administrative level.

All parties to the evaluation, management, and approval of conflicts are to make diligent efforts to maintain the confidentiality of personal or proprietary information to the extent allowed by law. 

E. Appeals

Academic staff have the right to appeal decisions that would require the Covered Individual to eliminate, in full or in part, the Outside Activity.

See COCI Appeals Procedures.

F. Conflict Review Committee

In matters of conflict of commitment or interest, the Responsible Official at each university will be advised by a Conflict Review Committee. When appropriate for conflict issues involving System Office staff, the President's designee will be advised by a System Conflict Review Committee, composed of University experts where relevant and System representatives.

G. Reports from Third Parties

Individuals who question whether a Covered Individual’s Outside Activity has been appropriately disclosed and managed should bring their concerns to that Covered Individual’s UEO. In cases where the UEO is involved in the Outside Activity, individuals may bring their concerns to the Responsible Official or designee. 

H. Non-compliance

If an Outside Activity was not disclosed, a conflict was not managed in a timely manner, or if a Covered Individual failed to comply with a conflict management plan, the Responsible Official, in consultation with human resources and/or other appropriate University offices, will oversee a retrospective review, mitigation report or other procedures required by law.

See Retrospective Review.

See Legal and Policy Authorities.

I. Interim Administrative Actions

At any time after a potential conflict of interest or commitment has been identified and before final disposition of the case, the UEO may take interim administrative action as required to comply with the law, to protect the objectivity of research, to protect the interests of students and colleagues, to preserve evidence, or to protect resources. Any interim action should be devised and taken as to create minimal interference with the University activities of the individuals involved, and in accordance with the University policies.

J. Records Retention

Conflict of interest files, including RNUAs and conflict management plans, must be retained and disposed of in accordance with State law. Departments must work with Records and Information Management Services (RIMS) to dispose of these records.

K. Exceptions

Any exceptions to the procedures described above shall be made only for good cause and with the approval of the chancellor/vice president of the respective university or the University of Illinois System President's designee for members of the University of Illinois System Offices.

II. Forms, Tools and Additional Resources

Glossary

START myDisclosures 

START myDisclosures Users’ Guide

START myDisclosures Reviewers’ Guide

RNUA Terms and Conditions

Examples of Activities Generally Not Requiring Prior Approval or Reporting

Examples of Activities that Require Prior Approval and Reporting

Activities that Require Management

COCI Appeals Procedures

University of Illinois Policy and Rules for Civil Service Staff Rule 16.01 Conflicts of Interest

Business and Finance Policy and Procedure Manual, Section 7.7 Procurement Conflicts of Interest

University of Illinois Ethics Line

Retrospective Review

Examples of Allowable Outside Activities Generally Not Requiring Prior Approval or Reporting

The following are examples of activities that are not normally considered conflicts of interest. They are exempt from disclosure, even if paid an honorarium stipend, or royalty, unless they are so extensive in time and effort that they present an actual or reasonably perceived conflict of commitment. 

1. Preparing, publishing, or presenting scholarly or creative works, including books, articles, and software.

2. Participating at professional conferences for the purpose of making scholarly presentations, conducting seminars or workshops.

3. Serving as a special reviewer or on a review panel for academic or governmental organizations.

4. Serving as a reviewer or editor for a scholarly journal.

5. Participating in a clinical practice plan approved by the University of Illinois Board of Trustees.

6. Receiving royalties under the University's royalty distribution policies while currently employed or otherwise appointed by the University.

7. Earning income from passive investments such as interest or dividends from banks, mutual funds, or stocks and bonds that do not otherwise create a conflict of interest with the Covered Individual’s University responsibilities. 

If you are paid an honorarium or receive royalties or compensation for activities noted above, please be aware of the following:

Though these activities generally do not require disclosure under this Policy, the State Officials and Employees Ethics Act restricts the acceptance of honoraria or travel expenses from prohibited sources generated while in the Covered Individual’s University capacity, and federal or state agencies may impose additional disclosure requirements. For further information, consult with the University Ethics and Compliance Office regarding restrictions on the acceptance of honoraria from prohibited sources.

Examples of Activities that Require Prior Approval and Disclosure on the Report of Non-University Activities

The following activities represent examples of actual or perceived conflicts of commitment or interest. The list is not all-inclusive and is intended to provide guidance. All examples are assumed to include both for-profit and not-for-profit entities.

1. Consulting work that is reasonably related to your University Responsibilities or scholarly expertise.

2. Conducting research that is reasonably related a Covered Individual’s University Responsibilities or scholarly expertise for an entity other than the University of Illinois.

3. Teaching or training that is reasonably related to a Covered Individual’s University Responsibilities or scholarly expertise.

4. Using University resources to conduct research that is sponsored by an entity in which the Covered Individual or their immediate family member has a financial interest or fiduciary role.

5. Conducting testing or clinical trials of products, devices, or services owned or controlled by an entity in which the Covered Individual or a member of their immediate family has a financial interest or fiduciary role.

6. Diverting research opportunities from the University to any external entity, (e.g., another academic institution, non-profit organization, federal laboratory, business, or consulting entity in which the Covered Individual or a member of their immediate family has a financial interest or fiduciary role).

7. Submitting grant proposals or making subaward arrangements involving the purchase of goods or services from an entity in which a Covered Individual or a member of their immediate family has a financial interest.

8. Serving in an executive or managerial capacity or holding financial interests in an entity in one's field of research.

9. Serving on the board of directors or a major advisory committee of an entity that sponsors the Covered Individual's research or provides gift funds for the use of the Covered Individual or his/her department.

10. Utilizing University students or employees in the staff member's University research sponsored by an entity in which the Covered Individual has a financial interest.

11. Conducting consulting or other Outside Activities involving University students or other University staff.

12. Utilizing University students or employees in the Covered Individual's University activities supported by gift funds from an entity in which the Covered Individual has a financial interest.

13. Serving in an executive or managerial capacity or holding a financial interest in an entity doing or seeking to do business with the University.

14. While acting in the context of the Covered Individual’s University duties, making professional referrals to an entity in which a Covered Individual or a member of their immediate family has a financial interest.

15. For academic staff with greater than 50% appointment, spending more than one day per seven-day-week, averaged over the contract period, on Outside Activities.