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Disclosure of Conflicts of Interest and Commitment 2005-06 Awareness

This guide outlines the importance of disclosing conflicts of interest and commitment at NCSU to mitigate risks and maintain institutional integrity. It provides insight into who should disclose, what information is required, when to disclose, and how to manage conflicts through management plans. Examples and consequences of compliance/non-compliance are highlighted, along with detailed instructions on disclosure maintenance and external professional activities for pay.

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Disclosure of Conflicts of Interest and Commitment 2005-06 Awareness

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  1. Disclosure of Conflicts of Interest and Commitment2005-06 Awareness Debbie Hunt – Special Advisor for Audits and Assessments Matt Ronning – Associate Vice Chancellor for Research and Compliance

  2. Why disclose? • Mitigate risk to the disclosing party and to the institution • Maintain confidence in NCSU’s self-regulation of inherent and natural conflicts of interest • The criminal statute of NC, NCAA regulations, and UNC System Policy

  3. Who discloses • Every EPA employee: • All EPA Professionals • Coaches • and Faculty in the colleges

  4. What is disclosed? • Significant financial interests • $10K and more than 5% • Example – Sports camps • Associations with outside entities • As it may involve/influence decision-making as a University employee • Note: Disclosure encompasses employee or family member living in same household

  5. When to disclose? • Renew comprehensive disclosure annually – late summer – In process now (July 2005) • Update disclosure perpetually throughout the disclosure year • As circumstances change • Watch for EPAP that creates a COI and update COI accordingly • EPAP system now electronic and integrated with COI

  6. How/Where? • All covered employees must utilize the web system • New system guides employees to answer only required questions based on each response given • Approvals and certifications are electronically routed to the Athletic Director instantaneously http://www.ncsu.edu/sparcs/coi

  7. Management Plans • When a real or perceived conflict exists • Establish parameters of operating with the conflict • Eliminate conflicts if management is impossible • Management plans should naturally fall out of the disclosure itself

  8. Management Plans Examples Example #1 • Athletics EPA employee’s spouse serves on the board of directors of the Boys and Girls Club and this organization rents NCSU athletic facilities. • Employee will not be involved in any decision-making/scheduling for rental of facilities or assignment of facilities to Boys and Girls Club. All such decisions will be elevated to the employee’s supervisor or the athletic director.

  9. Management Plans Examples, cont. Example #2 • Athletics EPA employee is co-owner of “Gymnastics R Us”, where some NCSU students or SPA employees work part time on the weekend. • EPA Employee does not directly supervise these students or SPA employees either at NCSU or at “Gymnastics R Us”. Recruitment is open to all NC State students and employees.

  10. Consequences • Consequence of compliance is mitigation of risk. • Consequences of non-compliance include NCAA sanctions, termination of employment, criminal prosecution.

  11. Disclosure Maintenance • Subject to increasing audit oversight • Ensure all disclosures are current • Watch out for new hires • COI System is a personnel file • Appropriate personnel should have access • Discuss COI at least twice per year at Athletics staff meetings and via other forms of communications that prove effective in your division

  12. External Professional Activities for Pay Notice of Intent aka – NOI and EPAP Why, When and How

  13. Request Permission for EPAP • NCAA Rules Require Full Disclosure of EPAP • State of NC rules prohibit EPAP without justification and consideration by the agency head • EPAP is a privilege enjoyed by academic institutions and must be carefully monitored

  14. When to Request Permission • At least 10 calendar days prior • Exceptional circumstances can arise. When you can’t meet the 10 day rule, then make certain you submit the request anyway for consideration by administration. • After the fact, still need to do it but need extra-ordinary justification.

  15. How to Request Permission • Web Based Utility • Fully integrated with COI • Routes automatically to Director’s office and where relevant Chancellor’s office. http://www.ncsu.edu/sparcs/coi/

  16. Questions • Ask questions now • Contact Matt Ronning (513-2148) or Debbie Hunt (515-7512) in Research Administration • Submit questions via web at http://www.ncsu.edu/research/guide/questions.html

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