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Policies

The following page outlines policies, statutes and regulations that are applicable to UF Faculty and Staff related to conflicts of commitment and conflicts of interest.

UF Conflicts of Commitment and Conflicts of Interest Policy

At UF, there is one COI Program, policy and a new electronic disclosure system (eDisclose). The process for review and approval of Outside Activities and Financial Interests are established in UF Policy 1-003 Conflicts of Commitment and Conflicts of Interest and administered by the UF COI Program.

Revised UF Policy 1-003* consolidates three areas of COI:

  • Conflicts of Commitment
  • Conflicts of Interest
  • Research Financial Conflicts of Interest

*In-unit faculty are subject to current Article 26 of the Collective Bargaining Agreement until bargaining is complete, so they must submit prior approval requests to engage in Outside Activities via UFOLIO.

Key Points for UF Policy 1-003

  • Establishes the expectations, requirements and processes for UF employees
  • Policy excludes employees with UF Health, Direct Support Organizations (DSOs), and any related or affiliated entities
  • Employees must receive approval prior to engaging only in select subsets of activities
  • Employees must report actual disclosable interests as defined under UF Policy 1-003

Disclosures will be required via eDisclose system for:

  • Pre Approval Requests (PAR) of a limited set of outside activities
  • Disclosable Interests on the Disclosure Profile
  • Completed outside activities
  • Obtained financial interests (e.g., equity or payment for services)

UF Policy 1-003 requires the reporting of Disclosable Interests for equity, consulting or other professional services, intellectual property rights, divestiture and cash pay-out, sponsored or reimbursed travel, board service, outside employment, other appointments, and innovation inducement prizes. See UF Policy 1-003 for full definition of each category.

Disclosable Interests must be disclosed on your “Disclosure Profile” in eDisclose. The Disclosure Profile is a dedicated workspace for you to report all your interests in one place that is kept updated throughout the year and certified at least annually.

  • Disclosure is required if the Disclosable Interest is related to an employee’s area of expertise at UF.
  • Disclosable Interests held by the UF employee or their Immediate Family must be disclosed.
  • The Disclosure Profile must be certified annually (you will also receive a system notification reminder).
  • Disclosable Interests must be added to the Disclosure Profile within 30 days of acquisition or discovery.

For more information, check out the Resources page for FAQs and helpful guides for disclosers and reviewers.

UF Policy 1-003 requires prospective approval prior to engaging in any Outside Activities:

  • where the outside Entity does business with the University, or
  • involve any use of University employees, students, facilities, equipment or other resources (more than incidental use)

Prospective approval is also required prior to these activities:

  • Textbooks and Classroom Works- if employee will require their students to purchase
  • Public Office- candidacy for or holding public office
  • Expert Witness- serving as a witness or reviewing documents for a medical legal matter or where the University, its employees or board members (in the course and scope of their university positions), UF Direct Support Organization (DSO), or UF affiliate is a party
  • Innovation Inducement Prizes- if the award is greater than $5,000 and pursued as an Outside Activity
  • Contracts with intellectual property terms that do not include the University provided UF Intellectual Property Rider

Article 26 of Collective Bargaining Agreement (CBA)

Current Article 26 of the Collective Bargaining Agreement remains in effect for in-unit faculty while bargaining is ongoing.

Under Article 26:

  • Current disclosure requirements for reportable outside activities and financial interests will remain in place
  • In-unit faculty will continue to use UFOLIO to request approval of outside activities
  • In-unit faculty researchers will also report Disclosable Interests in eDisclose

UF College of Medicine – COI Policy and Covenant

UF Regulation Number: 5.0764: College of Medicine Policy on Pharmaceutical, Medical Device, and Biotechnology Industry Conflicts of Interest and Policy on Industry Academic Relations

The College of Medicine’s conflicts of interest policy applies to COM personnel at UF. Under COM’s COI Policy on Industry Academic Relations, all interactions between COM personnel and Industry must conform with the policy on specific activities, including:

  • Gifts
  • Pharmaceutical Samples and Educational Materials
  • On‐Site Access by Industry
  • Continuing Medical Education (CME) and Other Educational Activities
  • Travel to Meetings/Honoraria for Attendance
  • Authorship
  • Scholarships and Fellowships
  • Prohibition on Speaker Bureaus
  • Restrictions on Food/Entertainment

Additional restrictions on faculty clinical practice are regulated under College of Medicine: Clinical Faculty Teaching Appointments and Restrictive Covenants.

UF Intellectual Property Policy

UF Regulation 1.018 Works and Inventions and UF Intellectual Property Policy

The Intellectual Property Policy of the University of Florida is based on Section 1004.23 of the Florida Statutes. Under UF IP’s policy, the University is authorized to license, protect, and otherwise deal with the work products of University personnel.

UF Regulation 1.018 Works and Inventions requires all UF employees to disclose certain works and all inventions that an individual may develop or discover while affiliated with the University.

IP disclosure also required under Article 22 of the Collective Bargaining Agreement for in-unit faculty members and other employees in the collective bargaining unit.

UF employees may engage in outside consulting contracts with intellectual property terms if the University provided UF Intellectual Property Rider is incorporated into and made part of the consulting agreement. A Pre Approval Request (PAR) will be required for contracts with intellectual property terms that do not include the university provided rider, per UF Policy 1-003 .

Florida Code of Ethics for Public Officers and Employees (FCOE)

Part III Code of Ethics for Public Officers and Employees sets the standard of conduct for UF employees.

Chapter 112 Section 313 of the Florida Statutes prohibits University employees from self-dealing in employment or contractual relationship with an external entity which also does business with UF. It also prohibits such relationships that would create a conflict between a UF employee’s private interests and institutional responsibilities such as renting, leasing or selling realty, goods, or services to UF.

Under Florida Statute 112.313 (12), there are state exemptions allowing specific transactions between UF and an external entity which an UF employee has a private interest. Examples of University transactions which would require an exemption are:

  • Sole source of a supply such as equipment or product purchased by UF
  • UF sponsored research or IP licensing transaction made pursuant to sections 1004.22 or  1004.23, and specifically approved by the University President and the Chair of the University Board of Trustees
  • Total amount of the transaction between UF and business entity does not exceed $500 in a calendar year

UF COI Program will review Pre Approval Requests (PAR) for Outside Activities and Interests for applicable Florida Code of Ethics exemption and document any applied exemption.

Federal FCOI Regulations

UF COI Program partners with the Division of Sponsored Programs (DSP) to ensure compliance with sponsor requirements, including federal agencies COI disclosure and reporting requirements. For more information on research conflicts of interest, see the Research Conflicts of Interest page.

PHS

U.S. Public Health Service (PHS) Regulation eCFR :: 42 CFR Part 50 Subpart F — Promoting Objectivity in Research is intended to preserve the public’s trust that the research they support conducted without bias and with the highest scientific and ethical standards. The regulation establishes the standards to provide a reasonable expectation that the design, conduct, and reporting of PHS research will be free from bias resulting from investigators’ Financial Conflicts of Interest.

  • PHS regulation requires disclosure of Significant Financial Interests (SFI) prior to proposal submission, annually and within 30 days of discovery/acquisition by all Investigators, including subrecipient Investigators.
  • Institution must review Significant Financial Interests (SFI) to determine whether a Financial Conflict of Interest exists, and determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce or eliminate such conflict of interest.
  • The Institution must also report Financial Conflicts of Interest (FCOI) to the awarding sponsor component.

NSF

National Science Foundation (NSF), pursuant to NSF Proposal and Award Policies and Procedures Guide (PAPPG), requires conflicts of interest disclosures from all Principal and Co- Investigators, including subrecipient Investigators, prior to proposal submission and for institutional review, pursuant to NSF PAPPG – May 20, 2024.

Under NSF PAPPG, each investigator must disclose to a responsible representative of the organization all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children):

  • (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF; or
  • (ii) in entities whose financial interests would reasonably appear to be affected by such activities

Disclosure must be made at the time of proposal and to be updated annually, or when new disclosable interests are obtained.

DOE

Department of Energy (DOE) Interim Conflict of Interest Policy outlines disclosure requirements for Investigators who accept a DOE financial assistance award as required by federal regulations 2 CFR 200.112 — Conflict of interest. The interim COI policy closely aligns with COI regulations established by the Public Health Service at eCFR :: 42 CFR Part 50 Subpart F.

  • Investigators on a project funded by a DOE award are required to disclose Significant Financial Interests (SFI) and update disclosures at least annually.
  • Investigators must certify that each disclosure and updated disclosure is true, complete, and accurate with a certification statement as provided in DOE Interim COI Policy.
  • Under DOE interim policy, the role “Investigator” may include any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. By definition, collaborators, consultants, or graduate (master’s or PhD) students working on DOE projects may be considered an Investigator who must disclose significant financial interests.

NASA

National Aeronautics and Space Administration (NASA) published on 08/31/2023 Conflict of Interest Policy for Recipients of NASA Financial Assistance Awards which requires COI disclosures and proposal certifications from Principal Investigators, Co- Investigators and Key Persons participating in NASA-funded projects.

  • Investigators and key personnel must disclose all Significant Financial Interests that relate to any proposed or funded NASA research projects.
  • COI disclosures are required at the time of proposal and to be updated annually, or when new disclosable interests are obtained.

Related references

  • NASA Grant and Cooperative Agreement Manual (GCAM ) Oct.-2022, version effective October 31, 2022
  • Grant Information Circular GIC 23-07 conflict-of-interest-policy effective December 1, 2023, with revisions to GCAM section 3.3, Conflicts of Interest Policy and notification requirements.

  • Mailing Address

  • PO Box 115500
    Gainesville, FL 32611-5500

  • Phone - (352) 392-9174

  • Email - uf-coi@ufl.edu