COI for University Administrators

Conflict of Interest Responsibilities for Administrators

The University of Arizona has a responsibility to ensure integrity and transparency in managing the intersections of its public and private interests, thereby preserving the integrity of its research enterprise and the public’s trust. The University has implemented its Conflicts of Interest & Commitment Policy to assist University of Arizona administrators in applying and complying with the University’s requirements regarding training, disclosure, review, and reporting of conflicts of interest.  Additionally, the Office for Responsible Outside Interests offer the Institutional Conflict of Interest Training for University Administrators.

What is an Institutional Conflict of Interest?

An Institutional Conflict of Interest, for purposes of this Policy, describes a situation in which Institutional Financial Interests may affect or appear to affect decisions made on behalf of the institution in connection with its Missions. Careful balancing and management of the University’s competing interests becomes necessary when Significant Financial Interests of the University or of a University Administrator have the potential to influence or appear to influence the conduct of research or business and administrative decisions made by or on behalf of the University.

An University Administrator is defined as:

Any University Employee in a position of administrative leadership of a college, academic department, business, or other administrative unit, where a regular job requirement is to make institutional decisions on behalf of the University of Arizona. The role of a University Administrator includes, but is not limited to, the following positions (whether such positions are staffed on an interim, full-time, or part-time basis):

• University Senior/Associate/Assistant Vice Presidents
• University Provost
• University Senior/Associate/Assistant Vice Provosts
• University Deans
• University Vice/Deputy/Associate/Assistant Deans
• University Directors
• University Department Heads/Chairs
• University Business Officers/Managers
• University Division Chiefs, Center Heads/Directors
• University Employees with the authority to sign agreements on behalf of the University of Arizona or Arizona Board of Regents
• University Employees whose duties and responsibilities include contracting or services related to Research administration, Research contracting, Research compliance, responsible conduct of Research, sponsored projects services, or technology transfer and who are in a position to influence decisions or commit University resources in the performance of the University Employee’s duties and responsibilities.
• Individuals who serve as Chairs on the University’s Institutional Review Board committees, regardless of whether such individuals are University Employees.

What do University Administrators have to disclose?

University Administrators must disclose Institutional Financial Interests within 30 days of acquiring a new Institutional Financial Interests or a change to an existing Institutional Financial Interests, and at least annually.  Institutional Financial Interests means:

1.  A University Administrator’s Significant Financial Interest;
2. A University Administrator’s Significant Personal Interest;
3. A loan of any amount between a non-publicly traded entity and a University Administrator or their family member;
4. The University’s equity or similar interest in a publicly traded entity valued at more than $100,000 or any amount in a non-publicly traded for-profit entity;
5. Substantial gifts, including in-kind gifts, received from an actual or potential commercial research sponsor or an individual or entity that owns or controls products being studied or tested as part of the Research;
6. Gifts totaling $1 million or more, cumulatively, and other gifts determined by the University’s Conflict of Interest Program to be substantial;
7. Any agreement with an external entity that includes the right for the University or a University Administrator or their family member to receive payments, royalties or other income from the commercial development or sale of an investigational product that is the subject of University Research;
8. Ownership by the Arizona Board of Regents (ABOR), on behalf of the University, of a patent and/or other intellectual property right in or sponsorship of an investigational new drug (IND) or device (IDE) application with respect to any drug or device for which human subject Research will be conducted;
9. Donation and sponsorship funds.

How to Disclose:

Prior to disclosing, please complete the Institutional Conflict of Interest Training for University Administrators.

For detailed instructions for completing your disclosure, please see Instructions for Submitting an Annual Disclosure Certification.

Please contact the Office for Responsible Outside Interests at coi@email.arizona.edu or (520) 626-6406 for assistance.