FAQs Regarding the Conflict of Commitment and Reportable Outside Activities Policy

Capitalized terms are defined in the policy. Please refer to the Definitions sectiona.

  1. What is an Institutional Conflict of Interest?
  2. What is an Institutional Financial Interest for the University?
  3. What is an Institutional Financial Interest for a University Official?
  4. Who is considered a University Official?
  5. Who is required to submit a financial disclosure statement?
  6. I work in the office of a University Official. Do I need to submit a financial disclosure statement?
  7. My spouse, parent, or other immediate family member is a University Official. Do I need to submit a financial disclosure?
  8. Are employees excluded or exempt from this requirement?
  9. Is there a specific form or template I should use?
  10. How often do I need to submit a financial disclosure statement?
  11. I completed a financial disclosure statement last year. Nothing has changed; why do I have to submit a new one?
  12. Do I need to wait for approval to engage in the reported activity?
  13. How often are institutional conflicts reviewed?
  14. I submitted my financial disclosure statement; when can I expect to receive a response?
  15. If the circumstances of an Institutional Conflict of Interest change after I receive permission to engage in it, do I need to do anything?
  16. If I do not report a potential Institutional Conflict of Interest, what are the consequences?
  17. What kind of conflicts are to be eliminated as opposed to mitigated or managed?
  18. If a conflict is identified, who will determine how that conflict should be addressed?
  19. Will I get to be involved in determining how best to mitigate or manage the conflict?
  20. How is the conflict management process different when the conflict involves University research?
  21. I am co-founder of a company, but I do not have any income from this relationship yet. Could this involvement represent an Institutional Conflict of Interest?
  22. Are financial disclosure statements subject to public disclosure?

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Q1.      What is an Institutional Conflict of Interest?

When an Institutional Financial Interest, or the financial interests of a University Official acting within their authority on behalf of the University, has either:

 

  • An actual effect on the University’s teaching, outreach activities and/or business transactions, or
  • The potential to affect, or reasonably appear to affect, the University’s research.

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Q2.      What is an Institutional Financial Interest for the University?

  1. Royalties or other payments from licenses or other technology transfer agreements related to University intellectual property rights, when such payments are in excess of $100,000 and received within the 12-month period immediately preceding the definitive agreement covering the research in question.
  2. Gifts/gifts-in-kind in excess of $1,000,000 received from a for-profit company supporting or proposing to support a sponsored project/activity.

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Q3.      What is an Institutional Financial Interest for a University Official?

  1. Royalties from licenses or other technology transfer agreements related to University intellectual property rights, when such payments are in excess of $25,000 and received within the 12-month period immediately preceding the definitive agreement covering the research in question.
  2. Honoraria or gifts in excess of $25,000 from an entity supporting or proposing to support a sponsored project/activity or conducting a business transaction with the University that are received within the 12-month period immediately preceding the definitive agreement covering the transaction or research in question.
  3. A position that gives rise to a fiduciary duty in a for-profit company.
  4. Equity or other ownership interest of more than 5% in a publicly traded company.
  5. Equity or other ownership interest in a non-publicly traded company.

 

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Q4.      Who is considered a University Official?

  • President
  • Provost
  • CFO
  • Executive Vice President
  • Chancellor
  • Senior Vice President
  • Vice President
  • Vice Chancellor
  • Vice Provost
  • General Counsel
  • Dean
  • Assistant or Associate Dean of Research
  • Director of Intercollegiate Athletics
  • Director of Audits
  • Director of Compliance
  • Director of Procurement
  • Comptroller
  • Institutional Official, Human Research Protection Program
  • Director, Human Research Protection Program
  • IRB Administrator
  • IRB Members

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Q5.      Who is required to submit a financial disclosure statement?

All University Officials as defined by the policy must submit a financial disclosure statement at the time of appointment and annually thereafter.

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Q6.      I work in the office of a University Official. Do I need to submit a financial disclosure statement?

No. Only the University Officials themselves need to submit a financial disclosure statement.

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Q7.      My spouse, parent, or other immediate family member is a University Official. Do I need to submit a financial disclosure?

No. The University Official is the only one who needs to submit a financial disclosure statement. The statement the University Official submits will include any Institutional Financial Interest held by immediate family members.

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Q8.      Are any employees excluded or exempt from this requirement?

This requirement applies to all University Officials without exception. If you are a University Official as defined by the Policy, you must complete the form. No other University employees are required to complete a financial disclosure statement.

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Q9.      Is there a specific form or template I should use?

Yes.  Use this link to the online form.

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Q10.    How often do I need to submit a financial disclosure statement?

 Upon appointment and annually on the anniversary of your appointment.

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Q11.    I completed a financial disclosure statement last year. Nothing has changed; why do I have to submit a new one?

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Q12.    Do I need to wait for approval to engage in the reported activity?

No. The Institutional Conflicts of Interest form is different from the Reportable Outside Activity form. It is used to report existing relationships rather than to seek permission or approval preemptively.

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Q13.    How often are financial disclosure statements reviewed?

Financial disclosure statements are reviewed at least twice a year by VPEC, EVPRP and IRB.

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Q14.    I submitted my financial disclosure statement; when can I expect to receive a response?

You may not receive a reponse.

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Q15.    If the circumstances of an Institutional Conflict of Interest change after I submit my report, do I need to do anything?

If the circumstances necessitate modifying a conflict mitigation or management plan, you should reach out to the Office of the Vice President for Ethics and Compliance (or IRB for research-related conflicts) for guidance.  If the change does not compromise an existing plan, you should submit your regularly scheduled financial disclosure statement on the anniversary of your appointment.

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Q16.    If I do not report a potential Institutional Conflict of Interest, what are the consequences?

Failure to disclose a potential Institutional Conflict of Interest may result in disciplinary action up to and including termination of the employment relationship.

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Q17.    What kind of conflicts are to be eliminated as opposed to mitigated or managed?

Conflicts that are unmanageable or inappropriate to manage will be eliminated. Any Institutional Conflict of Interest that may impact research involving human subjects or the integrity of the HRPP must be eliminated. VPEC and EVPRP will seek to only eliminate conflicts where there is no other option to manage them responsibly.

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Q18.    If a conflict is identified, who will determine how that conflict should be addressed?

The primary Officials tasked with creating a conflict management plan are VPEC and EVPRP. Additionally the following offices may be involved in identifying and managing conflicts on an ad hoc basis:

  • Office of the Comptroller
  • Office of Treasury Operations
  • Office of Financial Planning and Analysis
  • Procurement and purchasing departments
  • Purdue Research Foundation
  • Sponsored Program Services

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Q19.    Will I get to be involved in determining how best to mitigate or manage the conflict?

No. Anyone associated with an Institutional Conflict of Interest is required to recuse themselves from the relevant review process. The responsible, disinterested University Officials will determine the appropriate plan.

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Q20.    How is the conflict management process different when the conflict involves University research?

When a conflict involves University research, IRB is responsible for overseeing the conflict management plan prescribed by VPEC and EVPRP. The IRB has the final authority to decide whether the conflict is appropriately managed in relation to the proposed research and whether to allow the proposed research to be conducted as described in the associated protocol.

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Q21.    I am co-founder of a company, but I do not have any income from this relationship yet. Could this involvement represent an Institutional Conflict of Interest?

Accepting minor honoraria for giving lectures is allowed, whether from academic organizations or industry. If the honorarium is more than $1,000 annually, a Reportable Outside Activities Form must be submitted prior to engaging in the activity.

If you are an investigator on a sponsored project, the honoraria (of any amount) may need to be disclosed under the Individual Financial Conflicts of Interest policy.

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Q22.    Are financial disclosure statements subject to public disclosure?

Records may be subject to Indiana’s Access to Public Records Act or the federal Freedom of Information Act. Requests under either Act will be referred to the University’s public records officer in accordance with established University procedures.

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