Resources and FAQs

A Pre Approval Request (PAR) is the form used within eDisclose to request approval for an activity or acquisition of an interest. A PAR is only required in limited circumstances as explained in the Guide to What and When to Disclose and the revised UF COI and COC Policy.

Submit a Pre Approval Request (PAR) before:

i. Engaging in an activity or acquiring an interest that requires a PAR: the entity does business with UF, students/employees/UF resources will be used in an Outside Activity, collection of royalties from a textbook assigned to students, running for public office, pursuing an Innovation Inducement Prize as an outside activity. Details are available in UF COI and COC Policy and the Guide to What and When to Disclose.

ii. An already held interest or activity will meet the criteria for prior approval (e.g., your start-up company wants to employ UF students, use UF resources, or do business with UF).

Yes, you must submit a Pre Approval Request (PAR) and receive approval before your activity or interest meets any of the requirements to get prior approval, regardless of when the business was formed.

For example, if you founded a start-up company in 2023, you must report it on your Disclosure Profile now. If in 2026, your company decides to license a technology from UF Innovate, you must submit a PAR and receive approval for your company to do business with UF before executing the license.

Your direct supervisor and UF COI Program.

If you are providing expert witness services related to a medical matter, the Self Insurance Program (SIP) will also review the Pre Approval Request (PAR).

You may not hire anyone you supervise or advise at UF to work for you outside UF. If you have an ownership interest in a non-publicly traded entity, your students/trainees/direct reports may not work there. In addition, if department or college leadership hold equity in a non-publicly traded company, students under their purview may not intern or otherwise be employed at the company.

The Code of Ethics for Public Officers and Employees, adopted by the Legislature as Part III of Chapter 112, Florida Statutes, contains standards of ethical conduct and disclosures applicable to public officers, employees, candidates, lobbyists, and others in State and local government.

Part III of Chapter 112, Florida Statutes prohibits: 1) public employees from holding a material interest in an entity that does business with their public employer and 2) public employees from having an employment relationship (e.g., consulting) with an entity that does business with their public employer.

There are several exemptions to these prohibitions outlined in Part III of Chapter 112, Florida Statutes (112.313.12). The most common exceptions include: sole source justification for procurement, sponsored research and license agreements and purchases of less than $500 per calendar year.

You must submit a Pre Approval Request (PAR) if your entity (or the entity hiring you) does business with UF. When the COI Program reviews the PAR, it will identify if there is an applicable exemption, and the applicable exemption will be documented in the COI Program review.

Common examples of UF doing business with outside entities include: purchases, subcontracts, vendors, sponsored research, license agreements, and rental and lease agreements.

More than incidental use of UF supplies (e.g., phone, email, computer, lab supplies) and/or utilizing UF employee time to do work for your outside entity (e.g., employing students or trainees at the company, asking UF research administrators to write an SBIR/STTR proposal, requesting a business administrator to negotiate a consulting agreement for your outside activity or bringing company employees to do work in your UF lab space).

Use of UF resources requires an approved Pre Approval Request (PAR) before engaging in the activity.

A Disclosure Profile is a form within eDisclose that you keep updated with your Disclosable Interests as you acquire them (report within 30 days) and certify at least annually. If you have nothing to disclose, you will certify that annually.

For the initial system rollout, you will receive an email notification to complete your Disclosure Profile for the first time.

1. If you are a researcher (listed on UFIRST award or current myIRB protocol), you will receive an email notification during the first week of July.
2. If you are not a researcher, you will receive an email notification during the Fall 2025 system rollout. A rollout schedule will be posted on the COI Program Homepage.

After the system is fully implemented, you will receive an email notification to certify your Disclosure Profile annually. Please note, researchers may be required to certify more frequently to comply with sponsor policies. You will be prompted by email when a certification is required.

Yes, you must certify you have nothing to disclose.

Yes. Due to the UFOLIO data model, data cannot be transferred to eDisclose. You must complete a Pre Approval Request (PAR) for any of your current activities/interests that meet the new, limited criteria for advanced approval and report all Disclosable Interests to the Disclosure Portfolio. See Guide to What and When to Disclose.

i. Equity
Includes Stock, Stock Options or Ownership Interest (does not include mutual funds)

ii. Consulting or Other Professional Services
Service on an advisory, scientific advisory board or expert witness services

iii. Intellectual Property Rights
Royalties paid directly to individual from a non-UF entity in excess of $5,000 over 12 months

iv. Divestiture and Cash Pay-out
Sale of equity within the past 12 months

v. Sponsored or Reimbursed Travel
Travel paid on behalf of the Investigator or reimbursed to the Investigator by a non-UF entity in excess of $5,000 over 12 months

vii. Board Membership
Service on a Board of Directors, Board of Trustees or similar regardless of the entity’s profit status

viii. Outside Employment
Employment external to UF

ix. Other Appointments
Compensated or uncompensated (e.g., positions, appointments, fellowships, or talent programs)

x. Innovation Inducement Prizes
Awards of cash exceeding $5000 that recognize work performed in the area of a faculty member’s Institutional Expertise that are distinct from grants, contracts, or gifts awarded in advance for proposed work or awarded to winners of competitions including challenge prizes by federal or non-profit agencies requiring the attainment, within a specific time frame, of specific material, technology translation, or commercialization goals. 

Activities completed as part of UF Institutional Responsibilities, even if remuneration is received, do not qualify as Disclosable Interests. This includes any activity you do as part of your assigned research, clinical, teaching, administrative, extension, or service responsibilities that form the basis for supervisory assessment of your UF job performance. An Institutional Responsibility is documented through a Faculty Assignment Report, Effort Report, or Travel Authorization Request (TA) as applicable.

The following are not Disclosable Interest and do not require a Pre Approval Request (PAR):

• Required jury duty.
• Serving in the United States Armed Forces or other branches of the military.
• Signing an amicus brief when a University entity is not a party. When signing an amicus brief, an employee is permitted to state their position with the University but must make clear that they are signing the amicus brief solely in their personal capacity.
• Receiving honors, academic awards, or an honorary degree from a non-profit institution that are Cash Value Prizes and not Innovation Inducement Prizes.
• Taking Sabbatical or Professional Development Leave.
• Serving as a program manager for a United States federal agency or working on an assignment through the Intergovernmental Personnel Act or a similar federal program.
• Participating in the Fulbright (Scholar) Fellowship program.
• Performing activities that are part of employee’s Institutional Responsibilities, even when external compensation is provided. This includes, but is not limited to:
  • Participating in scientific or educational conferences, invited colloquia or other events while representing the University.
  • Performing peer review, proposal review for a United States federal or state government sponsor or non-profit organization, conference committee or journal editorial duties while representing the University.
  • Research activities approved and coordinated through the University including research by Investigators conducted at Entities as part of a University-sponsored project or research funding received by the University.
  • Membership in an academic or professional society (however, serving on the Board and carrying a fiduciary role requires disclosure).
  • Serving as an external member of a thesis, dissertation, or promotion committee.

If the activity is related to your area of expertise or profession, it is related to your Institutional Responsibilities (e.g., owning a bed and breakfast is unrelated for biomedical engineering faculty, but is related for tourism and hospitality management faculty).

A Malign Foreign Talent Recruitment Program (MFTRP) a “program, position or activity” sponsored by a Foreign Country of Concern; involves compensation or remuneration; and contains problematic obligations or activities. Additional details are available on the RISC website: Foreign Talent Recruitment Programs.

As part of the national discussion of inappropriate foreign influence on U.S. research, many federal sponsors have cited MFTRP as posing a particular threat to the U.S. research community. Federal sponsors consider participation (even by non-researchers) in these programs to increase UF’s overall risk profile. As such, MFTRPs are unallowable at UF, and due to sponsor requirements, certification that you are not in an MFTRP is necessary.

Disclosers receive email notifications when they need to update/certify their Disclosure Portfolio or respond to a reviewer’s question.

Reviewers receive an email notification when they need to review an annual certification of Disclosure Portfolio or a Pre Approval Request (PAR), and if a discloser responds to a question they asked.

No, eDisclose does not allow for you to assign a proxy.

The eDisclose Resources page includes instructions on how to use eDisclose.

Beginning 8/23/25, eDisclose will have two-way integrations with UFIRST and myIRB to reduce researcher burden and increase transparency into the research COI review process. Details of the integration are available in the Guide to eDisclose, UFIRST and myIRB Integrations.

If you add a new Significant Financial Interest (SFI, as defined by the UF COI and COC Policy), eDisclose will prompt COI Program review in the background (“Research Portfolio Review”) to determine whether your new SFI creates a Financial Conflict of Interest (FCOI) with your ongoing research studies that must be managed.

When you certify your Disclosure Profile, you are presented with a list of your current research studies. Next to each study is a button labeled “Update”. Any comments left using this “Update” activity are provided to the COI Program and are considered when determining whether there is a Financial Conflict of Interest (FCOI).

The COI Program may reach out to you via eDisclose with questions when assessing new research or a newly disclosed Significant Financial Interests (SFI).

A Management Plan documents strategies to mitigate research bias that could result from a Financial Conflict of Interest (FCOI). The plan identifies inherent controls in the research that mitigate bias (e.g., blinding, objective endpoints) and additional controls placed on the study (e.g., limited roles for conflicted investigators, disclosure).

Management Plans are required when the COI Program determines a Financial Conflict of Interest (FCOI) exists for a research study. An FCOI is when a Significant Financial Interest (SFI, as defined in the UF COI and COC Policy) is related to a project and will directly and significantly impact the design, conduct, or reporting of research.

When Management Plans are required, the COI Program drafts them with input from the conflicted investigator and potentially others, such as the college, department, or other investigators on the research study. The COI Program will then approve the plan or, beginning in Fall 2025, assign it to a Research COI Committee agenda.

No. The UF COI and COC Policy documents the longstanding principle that as a highly active research institution, UF employees must conduct research as part of their Institutional Responsibilities.

Additional guidance regarding start-up companies, part-time employees, and what constitutes research conducted as part of your Institutional Responsibilities is available in the Guide to Outside Research Restrictions.