Applicability of Conflict of Commitment Requirements

  1. All full-time (0.50 UA FTE or greater) University Employees must disclose their Outside Activity and receive prior approval from their supervisor – department head and dean for faculty – prior to engaging in the disclosed Outside Activity.  Agreements with foreign entities, the original and a translated version, must be attached to the disclosure.
    • Supervisors – department head and dean for faculty – are responsible for (1) reviewing all Outside Activity, (2) identifying Conflicts of Commitment and (3) ensuring they are properly mitigated through implementation of a management plan or elimination.  
    • OROI will process management plans for signature and upload a copy to eDisclosure.  OROI is also available to assist with developing management terms and/or drafting management plans.  
    • Full-time University Employees cannot engage in an Outside Activity until it has been approved and the management plan, if required, is fully executed.

 

  1. All Investigators, regardless of their UArizona FTE, are responsible for disclosing their Outside Activity, including all Other Support.  Agreements with foreign entities, the original and a translated version, must be attached to the disclosure.
    • Supervisors – department head and dean for faculty – are responsible for (1) reviewing all Outside Activity and Other Support, (2) identifying Conflicts of Commitment and (3) ensuring they are properly mitigated through implementation of a management plan or elimination.  
    • OROI will process management plans for signature and upload a copy to eDisclosure.  OROI is also available to assist with developing management terms and/or drafting management plans.  

 

  1. PIs are responsible for identifying the Investigators on their project.  The following guidance is available to assist PIs in making that determination: Who is an Investigator? and Identifying Investigators & COI Disclosers.

 

  1. All disclosures must be made in eDisclosure.  Once an Outside Activity or Other Support is disclosed in eDisclosure, it will persist across the discloser’s future certifications.

 

  1. Reviewers should rely on OROI’s Guidance for Reviewing Outside Activity & Other Support when making a COC determination.

 

  1. Being a party to/participating in a malign foreign talent program is prohibited.  Individuals should contact OROI (coi@arizona.edu) for review of agreements/documents to determine whether a foreign talent program is a malign foreign talent program.

 

  1. To request a preliminary COC review for a prospective DCC, the prospective DCC can submit a disclosure here: Conflict Disclosure Form for Subcontractors, Consultants, and Collaborators.  (Select “Designated Campus Colleague Pre-Review” as Reason for Disclosure and Disclosure Type. This pre-review will not result in a fee to the individual.)

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