If the phrase, “conflict of interest” brings to mind problems or worries, put your mind at ease. Just because someone has a conflict of interest (COI) does not mean they are doing anything wrong. Identified COIs are a recognition that an external interest or duty might overlap with the responsibilities someone has at the University of Louisville (UofL).
UofL has policies and procedure available at http://louisville.edu/conflictofinterest to address conflicts of interest to ensure unbiased university transactions. The process includes: population identification, disclosure, review, management, and oversight.
UofL decides who must comply with the policy – Covered Persons. The disclosure population is defined at http://louisville.edu/conflictofinterest.
The policy outlines external activities/interests to disclose on the Attestation and Disclosure Form (ADF). The ADF is the tool for your reporting of external interests and activities, as well as clarifying your roles and activities at UofL. External interests related to a Covered Person’s UofL duties must be reported on the ADF. These include: company ownership, extra employment, or consulting, lectures, or speaker bureau actions for external entities. Tip Sheets for guiding disclosure are available at http://louisville.edu/conflictofinterest. ADF questions cover a wide variety of items on the nature of the activity/interest, the external body involved, whether other UofL employees take part, etc.
ADF review reveals real or perceived COIs. The Conflict of Interest and Commitment (COIC) Office works with the Conflict Review Board to develop management plans for identified COIs. Not everyone that completes an ADF has external activities/interests. Also, UofL does not identify all disclosures as a COI. The review considers the filed information, the role (s) the individual serves at UofL and boundary between these items to decide the existence of a COI. If a COI exists, then management is the next step.
Management plans are tools UofL uses to mitigate identified COIs. These plans guide Covered Persons with COIs to ensure external events/interests do not bias UofL activities. It might call for an extra review of collected data, or having someone else prepare billing paperwork, or naming another individual as an adviser to students working on the project. Each plan clause should work in concert with the others to provide the proper protections for UofL activities. To ensure the plans are working as intended, they must be monitored.
Monitoring occurs at various levels. First line of defense is the Covered Person. The Covered Person is in the best position to know when the disclosure is no longer applicable. Communicating changes to the COIC Office can lead to changes in the plan. UofL also relies on the individual’s direct supervisor, or Appropriate Authority. These individuals are closely aware of the Covered Person’s institutional responsibilities and can monitor how the plan is affecting execution of those duties. Next, we have the COIC office itself. Information can be identified from external sources/reports that might have bearing on the management plan. Further, it is the COIC Office’s responsibility to keep up-to-date with the best practices around COI identification and management.
While COIs can be complex, we hope that this article serves as a brief, but helpful introduction. If you have more questions or concerns related to COIs, please contact the COIC Office at firstname.lastname@example.org.
Filed by the Conflict of Interest and Commitment Office 03/23/21