Conflict of Commitment and Interest Policy Procedures

1. Terms defined in the Policy.
2. Other terms used in this Procedure
1. Ancillary Review: Review of pre-approval requests, certifications, and management plans by individuals other than the Covered Individual’s home department.
2. Conflict: Refers to conflict of commitment or interest as defined by the policy. As stated in the policy, conflicts may be actual, potential, or perceived.
3. Discloser: Refers to the Covered Individual.
4. Disclosure Profile: A form in UIC Research COI submitted by the Covered Individual to report Outside Activities over the last academic year and current and ongoing Outside Activities.
5. Disclosure: The act of requesting approval to engage in Outside Activities through the Pre-Approval Request form and the reporting of Outside Activities on the Disclosure Profile.
6. Foreign entity: An entity that is either based, headquartered, or legally registered outside the United States.
7. UIC Research COI: UIC’s online application for disclosure and review.
8. Request Pre-Approval: A form in UIC Research COI submitted by the Covered Individual to request prior approval for new Outside Activities.
9. Reviewer: Includes UEO(s) for the Covered Individual’s home department, secondary appointments, the next higher administrative level of review following the home department appointment, the responsible official or designee, administrators in the Conflict of Commitment and Interest Office, any individuals or organizations assigned to ancillary review, individuals assign as assistants to support the review by the UEO.

1. Request Pre-Approval
1. Covered Individuals are required to request and obtain approval from their UEO prior to engaging in Outside Activities using the Pre-Approval Request form in UIC Research COI.
2. Covered Individuals will provide the following information on their Pre-Approval Request:
1. The entity name;
• If the entity is already listed in UIC Research COI, select the entity; or
• the entity is not listed in in UIC Research COI, enter the name, whether the entity is publicly traded, whether the entity is foreign, and whether the entity is a UIC startup;
2. The applicable disclosure type;
3. The Covered Individual’s anticipated time commitment to the Outside Activity;
4. The anticipated compensation (value in dollars);
5. Whether activity with the entity is related to the Covered Individual’s University Responsibilities;
6. Whether the Covered Individual receives funding or in-kind support for research activities from the entity;
7. Whether the Outside Activities will or may involve any university students or personnel.
8. The Covered Individual may include in the Pre-Approval Request agreements, grants, or contracts with the Entity. Documents should be uploaded to the UIC Research COI application in the Pre-Approval Request; and
9. If the Covered Individual has any role in a university sponsored research program and the Pre-Approval request type is Foreign Government Talent or Recruitment Program, the Covered Individual must include in the Pre-Approval Request all agreements, grants, or contracts with a foreign entity. Documents must be uploaded to the UIC Research COI application in the Pre-Approval Request.
3. Upon commencement of pre-approved activity the Covered Individual will need to update their Disclosure Profile and add the Entity as a Disclosure annually.
4. Regardless of prior approval, engagement in Outside Activities must be included on the Disclosure Profile within 30 days of commencement of the activity when required by a sponsor or other policy.
5. When Outside Activities occur without prior approval then retrospective review is required.
2. Disclosure Profile Update
1. Covered Individuals will update their Disclosure Profile in UIC Research COI, even if no Outside Activities are reported:
1. Upon or within 30 days of the start of a new University appointment;
2. When a change in reported Outside Activities occurs;
3. When required by granting agency;
4. Annually during the coordinated disclosure process; and
5. Upon or within 30 days of the start date for an approved Outside Activity when required by a sponsor or other policy.
2. Covered Individuals will provide the following information on their Disclosure Profile for each entity:
1. The entity name;
• If the entity is already listed in UIC Research COI, select the entity; or
• the entity is not listed in in UIC Research COI, enter the name, whether the entity is publicly traded, whether the entity is foreign, and whether the entity is a UIC startup;
2. Relation to the discloser;
3. All applicable disclosure types;
4. The Covered Individual’s time commitment to the Outside Activity;
5. Whether activity with the entity is related to any of the Covered Individual’s University Responsibilities;
6. Whether the Covered Individual, or Immediate Family Member, receives funding or in-kind support for activities from the entity;
7. Whether any university resources were used by the entity;
8. The estimated financial interest (e.g., compensation or value of equity) in the last 12 months;
9. The Covered Individual may include in the Disclosure Profile agreements, grants, or contracts with the Entity. Documents should be uploaded to the UIC Research COI application as a supporting document in the Disclosure Profile on the form for the Entity.
10. If the Covered Individual has any role in a university sponsored research program and the disclosure for the entity includes the disclosure type Foreign Government Talent or Recruitment Program, the Covered Individual must include in the Disclosure Profile all agreemaents, grants, or contracts with a foreign entity. Documents must be uploaded to the UIC Research COI application as a supporting document in the Disclosure Profile on the form for the Entity.
3. Exemption for Covered Individuals with 0% unpaid appointments that have University Responsibilities involving only didactic teaching or non-research appointments.
1. A UEO may grant an exemption to a Covered Individual from reporting if the Covered Individual has a 0% unpaid appointment and their University Responsibilities involve only didactic teaching and/or non-research.
2. The exemption must be completed on a year-by-year basis by the UEO.
3. The UEO must state the reason for the exemption.
4. COCI Office will withdraw COCI Certification for Covered Individuals granted exemption.
5. The UEO can revoke the release at any time if the Covered Individual no longer meets the exemption criteria. The UEO must inform the COCI Office of the changes and request a new COCI Certification be created for the Covered Individual.
6. The exemption for the temporary release will be removed by the COCI Office at the end of the academic year or if there is identification that the individual does not meet the exemption requirements.
4. Temporary Release from Disclosing Outside Activities Due to Medical Leave
1. In cases where a Covered Individual is unable to complete an annual Disclosure Profile update to comply with the University policy due to medical leave, the UEO of the Covered Individual’s home department may grant a temporary release by adding an exemption to the Covered Individual’s Disclosure Profile. The release exempts the Covered Individual from completing the Disclosure Profile update until the medical leave ends and the Covered Individual will not receive notifications to update their Disclosure Profile.
2. A UEO may not grant a temporary release to a Covered Individual from reporting if the Covered Individual continues to conduct, administer, or applies for a sponsored program while on leave.
3. The UEO must ensure that any Covered Individual who is excused from reporting completes the Disclosure Profile update upon return to work. The UEO must remove the exemption from the Covered Individual’s Disclosure Profile.
4. The UEO can revoke the release at any time.
5. The exemption for the temporary release will be removed by the COCI Office at the end of the academic year or if the temporary release is no longer warranted.

1. Overview
1. Review of Requests for Pre-Approval and COCI Outside Activities Certifications are conducted by UEO of the unit(s) in which a Covered Individual has an appointment and the COCI Office.
2. When a COCI Outside Activities Certification requires a second level of review the COCI Office will route the certification and management plan to a second level administrator following the Covered Individual’s home appointment. The second level UEO will be assigned as a required ancillary review on the management plan.
2. UEO Responsibilities
1. The UEO may seek, at any time, the advice of the dean, director, responsible official or designee, or other individual responsible for the process that generated the pre-approval request or certification.
2. The UEO will work with the Covered Individual to identify, evaluate, and either manage or deny Outside Activities due to conflicts of commitment or interest.
3. The UEO will indicate on the review of the Pre-Approval Request if they recommend approval of the requested activities. When the UEO recommends approval for the requested activities, the UEO should provide comment and may provide a draft management plan when the future activities will present a conflict of commitment or interest.
4. The UEO will indicate on the review of the certification if they recommend additional action, such as assigning the certification to a management plan to manage or eliminate conflicts of commitment or interest. When additional action is recommended, the UEO must provide comments to specify which entity or entities require additional action or attach a draft management plan and specify the applicable entity or entities.
5. The COCI Office will complete the review of the certification and initiate the management plan workflow.
6. If the UEO denies activities on a Pre-Approval Request or COCI Outside Activities Certification, a second level of review must occur, and the decision of the second level reviewer will be final, subject only to appeal on procedural grounds. The UEO must provide comment or a document explaining the decision and when the Outside Activity already exists, a plan for the Covered Individual to eliminate the denied Outside Activity.
3. Principle Duties for UEO
1. Evaluate all potential conflict situations reported or known to them before approving Pre-Approval Request or COCI Outside Activities Certification;
2. Obtain sufficient information to make informed decisions under the policy;
3. Determine whether the use of university resources, if requested or identified, is beneficial or detrimental to the University’s mission. If UEO is not custodian of the resources, then the UEO must document the approval or agreement from the appropriate office that is the custodian of the resources;
4. When a conflict is identified, and a decision is made to allow the Outside Activity to proceed, develop an appropriate management plan with the Covered Individual that specifies the management mechanisms and review timeline;
5. Implement management plans for activities that present conflicts of commitment or interest or complete monitoring reports with the annual COCI Certification review;
6. Implement management plans for family relationships that present conflicts of interest or complete monitoring reports with the annual COCI Certification review;
7. Deny any activity that presents a conflict that cannot be managed, or if a requested or disclosed activity is prohibited by the University COCI Policy or any other university policy;
8. Notify Covered Individuals of the decision within 10 business days of receipt of the COCI Outside Activities Certification or Pre-Approval Request;
   Exception: This 10-business day notification requirement is modified during the annual coordinated disclosure process. The submission and review deadlines for that process are posted on the Vice Chancellor for Research website.
9. Monitor Outside Activities of Covered Individuals, complete annual monitoring reports for management plans, and oversee and regularly evaluate or update management plans; and
10. Notify appropriate university offices and responsible official if the conflict results in a performance issue, misuse of University resources, or a violation of University policies or procedures.
4. Multiple UEOs
1. When a Covered Individual holds paid appointments in multiple units, the UEO of each secondary appointment unit will serve as an ancillary reviewer. The ancillary reviewer will indicate their review of the annual COCI Outside Activities certification and Pre-Approval Request.
2. The ancillary review for secondary appointments does not prevent the completion of the review by the home unit. The Covered Individual’s home unit takes the lead in the review and approval of COCI Outside Activities Certifications and Pre-Approval Requests.
3. When a second level of review is required, the second level review follows the Covered Individual’s reporting line based on the home unit.
4. When a Covered Individual has a management plan, ancillary reviewer may request to be added as an ancillary reviewer on the management plan. The ancillary review for the secondary appointment is non-blocking.
5. Ancillary Review
1. Ancillary Review will be assigned automatically on Pre-Approval Requests and COCI Outside Activities Certifications for the following disclosed activities;
1. An entity that is foreign will be automatically assigned to the University Export Controls Compliance Officer;
2. An entity the includes travel outside the US will be automatically assigned to the University Export Controls Compliance Officer;
3. An entity that includes intellectual property will be automatically assigned to the University Office of Technology Management;
4. An entity that includes a foreign talent or recruitment program will be automatically assigned to the University Export Controls Compliance Officer and the University Research Security Officer.
2. Ancillary review may be assigned by the UEO or their assistant, or the COCI administrator on an as needed basis to an individual or an organization.
3. Ancillary review will be assigned as either blocking or non-blocking:
1. Blocking ancillary reviews must be completed before review of the pre-approval request or certification can be finalized by the COCI Office.
2. Non-blocking ancillary reviews provide the assigned ancillary reviewer or organization with access to the pre-approval request or certification but will not prevent the review of the pre-approval request or certification from being finalized by the UEO of the home department and COCI Office.
6. Revoking Approval
1. If at any time, the UEO perceives that the conflict management plan mechanisms are no longer effective, the UEO will work with the COCI Office to revoke approval of the management plan.
2. The UEO should evaluate the situation and revise the management plan to implement additional management mechanisms or eliminate the conflict.
3. The UEO of the home department shall inform the UEO at the second level when a management plan has been revoked.
7. Second Level of Review
1. A second level of review is required for any Outside Activities presenting conflicts of commitment or interest. The second level of review is not an appeal but is a required part of the review process. The review takes place at the next administrative level for the Covered Individual’s home department reporting line.
2. When activities that present conflicts of commitment or interest are approved with a management plan, the administrator at the second level of review has the duty to:
1. Review the Outside Activities and proposed management plan or monitoring report;
2. Request additional information, as needed, prior to approving the management plan or monitoring report; and
3. Work with the Covered Individual and first level UEO(s) to oversee the management plan and review monitoring reports.
3. When activities that present conflict of commitment or interest are denied, the administrator at the second level of review has the duty to:
1. Review the Outside Activities and statements from the UEO at the first level of review; and
2. Request additional information, as needed, prior to confirming the denial of the activities.
8. Principle Duties for the Responsible Official
1. Oversee and approve management plans prior to execution of licensing agreement for intellectual property and technology owned by the university;
2. Evaluate management plans for approved Outside Activities that present conflicts of commitment or interest to ensure conflicts are sufficiently managed;
3. Monitor the oversight of management plans;
4. Conduct investigations when there are allegations of violations of the policy;
5. Enforce compliance with the University policy in cases of violations of the policy and when necessary implement non-compliance oversight plans;
6. Monitor adherence to non-compliance oversight plans;
7. When Outside Activities are denied by the second level of review, serve as the arbiter of the appeal and make final determination on the review;
8. Ensure that any requirements for reporting of significant financial interests or conflicts of interest imposed by laws, regulations or contracts are met;
9. Report to external agencies, when required by law or contract;
10. Provide external agencies access to relevant documents for investigations or audits, when required by law or contract; and
11. Comply with public disclosure requirements of external agencies, when required by law or contract.

1. Conflict of Commitment and Interest Management Plans
1. COCI Conflict Management Plans involve:
1. The annual completion of the Disclosure Profile Update by the Covered Individual;
2. The evaluation of the certification and determination of approval or denial; and when Outside Activities are approved but present conflicts of commitment or interest,
3. The execution of a written conflict management plan.
2. Conflict management plans must be reviewed and approved by the UEO as part of the COCI Outside Activities Certification Review.
3. The management plan must be approved by the administrator at the second level of review.
4. If the responsible official or designee determines the conflict is not appropriately managed, then the responsible official will work with the UEOs to revoke approval and revise the management plan; or
5. If Outside Activities cannot be managed, then responsible official or designee will work with the UEOs to deny and eliminate the activities.
2. Nepotism Conflict of Interest Management Plans
1. Covered Individuals are required to disclose immediate family members on their Disclosure Profile when their University Responsibilities, including sponsored programs, involves an immediate family member.
2. Sponsored programs involving the Covered Individual’s immediate family members require nepotism management plan with oversight by the UEO of the Covered Individuals’ home department and ancillary review by the UEO of the administering unit when the project is outside the Covered Individual’s home department.
3. Nepotism Management Plans for sponsored programs will be assigned to all family members included on the Covered Individual’s Disclosure Profile.

1. Any UEO or administrator at second level of review involved in evaluating disclosures, negotiating, or administering conflict management plans must disclose in writing to the next administrative level any 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.
2. 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.

1. This committee will consist of at least three Covered Individuals appointed after consultation with the executive committee of the university senate.
2. The committee serves as advisory to the responsible official and will make recommendations to the responsible official regarding matters of university procedures, guidance, and reviews management of conflicts of commitment and interest and non-compliance.

1. Any person who questions whether a Covered Individual’s Outside Activity has been appropriately disclosed and managed or questions if the Covered Individual is complying with the requirements of a management plan should bring their concerns to that Covered Individual’s UEO or the responsible official or designee.
2. In cases where the UEO is involved in the Outside Activity, any person may bring concerns to the next higher level of reviewer, responsible official or designee.

1. The responsible official or designee, in consultation with human resources and other appropriate university offices, will oversee allegations of potential non-compliance.
2. Allegations of potential non-compliance may be received by the responsible official or designee through UEO, third parties or other. Allegations will be assessed by the responsible official or designee as “non-serious” or “serious” non-compliance.
3. Allegations of potential non-serious non-compliance are as follows:
1. These allegations are “easily correctable” meaning that they do not require convening an inquiry to reconcile. The correction will follow the retrospective review process outlined in Section IX of this Procedures document.
2. The Covered Individual will be granted a sufficient amount of time¹ to address the non-serious non-compliance. Non-serious non-compliance may become serious non-compliance if not addressed by the Covered Individual in a timely manner.
3. The responsible official or designee, in consultation with the Conflict Review Committee Chair, may determine the need for further investigation of the non-serious non-compliance.
4. Allegations of potential serious non-compliance may require an inquiry to assess allegations. The responsible official or designee may conduct an inquiry to determine the need for further investigation of the non-compliance.
5. The Covered Individual (with carbon copy to UEOs) will be notified in writing that an inquiry is being conducted to assess allegations of non-compliance and state the expectations of the Covered Individual to cooperate with the inquiry and comply with University policy and procedures.
6. The inquiry may include interviews and written responses from the individual(s) involved in the non-compliance allegation and individuals with oversight of the disclosure and management of the Outside Activities or university resources.
7. Information collected by the responsible official or designee will be shared with the Conflict Review Committee for review and determination on non-compliance.
8. Covered Individuals may be found in non-compliance with the policy if:
1. A Covered Individual failed to make a disclosure in accordance with the procedures;
2. An Outside Activity was not:
1. Approved prior to engaging in the Outside Activity; or
2. For ongoing activities, disclosed on the Covered Individual’s Disclosure Profile,
3. A conflict was not managed in a timely manner; or
4. A Covered Individual failed to comply with a conflict management plan.
9. The Covered Individual (with carbon copy to UEOs) will be notified in writing of the determination by the Conflict Review Committee. Any determination of non-compliance will require the Covered Individual to follow the procedures for a retrospective disclosure and review.
10. Violations of the policy identified by the retrospective disclosure and review procedure may require the UEOs to submit a mitigation report to the responsible official, which may result in further investigation or other procedures required by law.
11. The responsible official may take interim actions of the university taken prior to a determination that a violation occurred to comply with laws, regulations, or grant terms, to protect the interests of the University, including contractual obligations.

¹Sufficient amount is based on annual COCI disclosure deadline for Covered Individuals and the requirement to update disclosure within 30 days for changes to financial interest for investigators on sponsored programs or studies that require IRB review.

1. If a Covered Individual discloses Outside Activities on their Disclosure Profile after the activities have occurred and the Covered Individual did not obtain approval for the activities prior to engaging in the Outside Activities and disclosed, then the UEO must conduct the review of the Outside Activities retrospectively.
1. A letter stating the potential or actual non-compliance and requirements for the retrospective review will be sent to the Covered Individual.
2. The UEO must obtain from the Covered Individual a written explanation that documents why the Outside Activities were not reported prior to engaging in the Outside Activities or included on the Disclosure Profile and indicates whether the Outside Activities will continue or have ended.
3. The UEO must assess the retrospective disclosure and determine whether the retrospective Outside Activities present conflicts of commitment or interest; and whether mitigation is necessary. If mitigation is necessary, the UEOs and Covered Individual will work together to implement mitigation steps by proposing a mitigation report with corrective actions.
4. If the UEO determines there is no conflict of commitment or interest, the review is documented in the application and completed. No further action is needed to mitigate the non-compliance. The Covered Individual (with carbon copy to UEOs) will be informed in writing of the decision.
5. If the Outside Activities present conflicts of commitment or interest, the UEO must upload an explanation on how the conflict will be managed or eliminated. The UEO will indicate that they recommend additional action when there is a conflict of commitment or interest. The COCI Office will implement the process for the management plan workflow, including review by the second level in the Covered Individual’s home unit reporting line. The Covered Individual will review and indicate their acceptance of the management plan.
6. If mitigation is necessary, the UEO and the Covered Individual will work together to mitigate the effects of the undisclosed Outside Activity and unmanaged conflict by proposing a mitigation report with corrective actions.
2. If a Covered Individual does not comply with the management plan, then the UEO must conduct the review of the Outside Activities retrospectively.
1. A letter stating the potential or actual non-compliance and requirements for the retrospective review will be sent to the Covered Individual (with carbon copy to UEOs).
2. The UEO must document a written explanation that details the circumstances surrounding the non-compliance. The UEO may consult with the Covered Individual for additional information.
3. Any failure to comply with a management plan requires a second level of review. In consultation with the responsible official or designee, the UEOs must assess the explanation and determine whether mitigation is necessary. If mitigation is necessary, the UEOs and Covered Individual will work together to implement mitigation steps by proposing a mitigation report with corrective actions.
4. The UEOs must also consider, acknowledging past non-compliance, whether revoking approval for the Outside Activity is warranted.
5. When revoking approval is warranted, the UEO will update the management plan to state how the Outside Activities will be eliminated. The revised management plan will require approval by the first and second level reviewers. The Covered Individual will review and indicate their acceptance of the management plan.
6. When revoking approval is not warranted, the UEO will review the management plan to ensure that conflict is appropriately managed or update the management plan to include additional management and oversight. The revised management plan will require approval by the first and second level reviewers. The Covered Individual will review and indicate their acceptance of the management plan.
3. If a Covered Individual’s conflicts are not managed timely, then the UEO must conduct the review of the Outside Activities retrospectively.
1. A letter stating the potential or actual non-compliance and requirements for the retrospective review will be sent to the Covered Individual (with carbon copy to UEOs).
2. The UEO will include supporting documentation with the Covered Individual’s annual COCI Outside Activities Certification review. The UEO will provide a written explanation detailing the circumstances surrounding the failure to manage the conflict(s) and indicate whether or not additional action is necessary.
3. All conflicts not managed in a timely manner require a second level of review, in consultation with the responsible official or designee, will review the explanation and determine whether mitigation steps are necessary.
4. If mitigation is necessary, the UEOs and Covered Individual will work together to mitigate the effects of the unmanaged conflict by proposing a mitigation report with corrective actions.
5. The UEOs must also consider, acknowledging past non-compliance, whether revoking approval for the Outside Activity is warranted.
6. When revoking approval is warranted, the UEO will update the management plan to state how the Outside Activities will be eliminated. The revised management plan will require approval by the first and second level reviewers. The Covered Individual will review and indicate their acceptance of the management plan.
7. When revoking approval is not warranted, the UEO will review the management plan to ensure that conflict is appropriately managed or update the management plan to include additional management and oversight. The revised management plan will require approval by the first and second level reviewers. The Covered Individual will review and indicate their acceptance of the management plan.

1. A mitigation report details non-compliance and specifies any violations, how they are being mitigated or managed by corrective actions, or if they cannot be mitigated or managed.
2. The responsible official, with consultation from the Conflict Review Committee and/or CRC Chair, will review the mitigation report and determine if the report as proposed is acceptable or not acceptable. If not acceptable, the responsible official may determine that non-compliance cannot be mitigated or managed.
3. If the non-compliance cannot be mitigated or managed, then the responsible official will determine the need to investigate further.

1. The Covered Individual (with carbon copy to UEOs) will be notified in writing that an investigation is being conducted to further investigate non-compliance and state the expectations of the Covered Individual to cooperate with the investigation and comply with University policy and procedures.
2. If investigation of non-compliance is required, the responsible official will convene a special review committee to evaluate the non-compliance and make recommendations to the responsible official for corrective actions and, when necessary, sanctions.
3. Investigation may include conducting additional interviews, collecting information, and obtaining written responses from the individual(s) involved in the non-compliance and individuals with oversight of the disclosure and management of the Outside Activities or university resources. Information collected by the responsible official or designee will be shared with the special review committee.
4. When recommended by the special review committee, the responsible official will implement corrective actions and monitoring as part of a non-compliance oversight plan. The Covered Individual and UEOs will be notified in writing of the determination of the investigation (with carbon copy to UEOs).

1. At any time after a conflict of interest or commitment has been identified and before final disposition of the case, the UEO or responsible official or designee may take interim administrative action as required to comply with the law, to protect the integrity of the University, to protect the objectivity of research, to protect the interests of students and colleagues, to preserve evidence, or to protect university resources.
2. Any interim action should be devised and taken to create minimal interference with the University Responsibilities of the individuals involved, and in accordance with the University policies.
3. The Covered Individual and UEOs will be notified in writing of the decisions to take administrative actions and state the expectations of the Covered Individual and UEO to cooperate with the administrative actions.

1. Denials by the UEO
1. When the UEO denies a Pre-Approval Request to engage in a new Outside Activity or revokes approval for an existing activity on the Disclosure Profile, a Covered Individual may appeal the denial to the second level of review within 10 business days after receipt of the notice of denial.
2. In any appeal, the Covered Individual must present, in writing, the rationale for approval of the Outside Activity and may submit documentation or evidence supporting the appeal.
3. The administrator at the second level of review will evaluate the information provided, may request additional information from the Covered Individual or the UEO, and may seek advice from the responsible official or other individual responsible for the process which generated the disclosure.
4. Ordinarily, the second level of review must respond to an appeal within 10 business days of receiving either the appeal or information provided in response to requests for additional information.
5. If 10 business days pass without the second level of review notifying the Covered Individual of the outcome of the appeal, the Covered Individual has the right to take the appeal to the next administrative level, in which case the second level of review will be terminated, and the next administrative level will rule on the appeal.
6. The Covered Individual may choose not to take the appeal to the next level, and if so, any delay in determination by the second level of review will not be considered a procedural violation.
7. The outcome of the appeal is the approval or denial of the request to engage in the Outside Activities.
8. Denial of approval of an Outside Activity following an appeal to the second level of review is final, absent an appeal to the Vice Chancellor for Research or designee on procedural grounds.
2. Denials Initiated by the Second Level of Review
1. When UEO approval of a Pre-Approval Request or COCI Outside Activity certification is over-ridden at the second level of review, a Covered Individual may appeal the denial to the next higher level of administrative review within 10 business days after the Covered Individual receives notice of the denial.
2. The Covered Individual must present their rationale for approval of the Outside Activity, including documentation or evidence supporting the appeal.
3. Denial of approval of an Outside Activity by the next higher level of administrative review is final, absent an appeal to the Vice Chancellor for Research (VCR) or designee on procedural grounds.
3. Final Appeals Based on Procedural Grounds
1. Appeals on procedural grounds must be filed with the VCR or designee within 10 business days after the Covered Individual receives notice of the denial by the second-level reviewer.
2. The appeal must include a description of the procedures that were violated and may include documentation or evidence supporting the claim of procedural violation.
3. The VCR or designee shall, within 30 calendar days, either affirm or vacate the decision to deny approval of the activity and notify the Covered Individual and others concerned.
4. In making a decision on an appeal, the VCR or designee will consider the university’s obligations and interests as stated in the policy and whether fundamental fairness was afforded to the Covered Individual.
5. The VCR or designee will also consult, if possible, with the chair of the conflict review committee prior to issuing a decision.
6. This decision shall be final.

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

1. Any exceptions to the procedures described above shall be made only for good cause and with the approval of the chancellor.
2. Chancellor must document approval of expectations in writing.

1. Allegations confirmed through assessment by the Investigation by the responsible official (Procedures, Section VIII A-G) are subject to potential consequences for violations.
2. If non-compliance cannot be mediated through corrective action, the responsible official will make recommendations to the chancellor to determine the process to begin sanctions.
3. Nothing in this document is intended to diminish or replace the procedural rights of Covered Individuals under the Statutes.