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Supervisor Reviewer Guides

Annual Certification Review Instructions

For each direct report, supervisors will conduct an annual review of the Disclosure Profile in eDisclose prompted by a system email notification. To conduct an Annual Review, consider the following questions:

Are any of the Disclosed Interests part of the employee’s Institutional Responsibilities?

  • If a faculty member will include an activity on their Faculty Annual Report or a staff member is performing an activity as part of their UF job and representing UF, it should not be included on the Disclosure Profile. If you identify Institutional Responsibilities on the Disclosure Profile, before approving the annual certification, send a request for clarification in the system and require the employee to remove them from the Disclosure Profile.

Are any of the Disclosed Interests unallowable?

  • The UF COI and COC Policy prohibits: 1) Malign Foreign Talent Recruitment Programs and 2) Outside Research. If you identify one of these activities on the Disclosure Profile, your review must mark “yes” to the question asking if there is an unresolvable conflict of interest. The COI Program will then follow up with the discloser to ensure the discloser ceases the activity and the Disclosable Interest is removed from their Disclosure Profile.
  • For additional assistance identifying a Malign Foreign Talent Recruitment Program, visit the RISC website. For further clarification regarding what is considered Outside Research, consult Outside Research Restrictions.

Is Pre Approval required, and if so, has it been secured?

  • If a Disclosed Interest requires a Pre Approval Request (PAR), ensure the discloser has submitted one. If there is not a PAR on record, send a request for clarification in the system and require the employee to submit one. The UF COI and COC Policy states what activities require a PAR. What and When to Disclose provides a list of when a PAR is necessary.

Does anything disclosed create an unresolvable Conflict of Interest or Conflict of Commitment?

  • IF A DISCLOSED INTEREST PREVENTS THE EMPLOYEE FROM FAIRLY CARRYING OUT THEIR UF JOB OR A DISCLOSED INTEREST RESULTS IN PERSONAL GAIN FROM THEIR PUBLIC JOB AS A STATE EMPLOYEE, THAT IS AN UNRESOLVABLE CONFLICT OF INTEREST.
    • When you identify a potential conflict of interest, consider the following to determine if you can mitigate the conflict. If you mitigate the conflict of interest, by one of more of the following, confirm in your review that there is not a conflict of interest. 
      • Discloser alters their activities such that you are satisfied they can fairly carry out their UF position and they are not using UF resources or their UF position for personal gain.
      • There is an approved PAR identifying the Florida Code of Ethics exemption for the circumstances, when applicable.
    • If there is not a way for you to mitigate the conflict, indicate “yes,” there is a conflict of interest and explain the circumstances in the reviewer box. The COI Program will then ensure the Disclosable Interest is ceased and removed from the Disclosure Profile.
    • Note on Research Conflicts: The COI Program reviews all new sponsored research agreements and IRB protocols for relatedness to Significant Financial Interests that may create Financial Conflicts of Interest. This centralized function means you are not being asked to ensure research conflicts of interest are addressed in your annual review of the Disclosure Profile.
  • IF A DISCLOSED INTEREST PREVENTS THE EMPLOYEE FROM EFFECTIVELY CARRYING OUT THEIR UF JOB DUE TO TIME CONSTRAINTS OR OBLIGATIONS TO THE OUTSIDE ENTITY, THIS IS AN UNRESOLVABLE CONFLICT OF COMMITMENT.
    • If in your discussions with the employee, they can reduce the time or alter the activities such that you are satisfied they can successfully carry out their UF position concurrently with the Disclosed Interest, you have mitigated the conflict of commitment issue and you can confirm in your review that there is not an unresolvable conflict of commitment.
    • If there is not a way for the employee to alter their time commitment or activity such that the conflict of commitment can be resolved, indicate “yes,” there is an unresolvable conflict of commitment in your annual review and explain the circumstances in the reviewer box. The COI Program will then ensure the discloser ceases the Disclosable Interest and removes it from the Disclosure Profile.

Pre Approval Review Instructions

Supervisors review Pre Approval Requests in eDisclose prompted by a system email notification. To conduct the review, consider the following questions:

Is the request for an Unallowable Activity?

  • The UF COI and COC Policy prohibits: 1) Malign Foreign Talent Recruitment Programs and 2) Outside Research. If you identify one of these activities, deny the request. The COI Program will then follow up with the discloser. For additional assistance identifying a Malign Foreign Talent Recruitment Program, visit the RISC website. For further clarification regarding what is considered Outside Research, consult Outside Research Restrictions.

Is Pre Approval required?

Pre Approval Requests (PAR) are required only in limited circumstances (below). If a PAR is not required, request the discloser withdraw the PAR.

a) Business with UF: Outside entity does business with the university.

b) Use of UF Resources: Activity involves any use of university employees, students, facilities, equipment or other resources.

c) Textbooks and Classroom Works: Works for which employee will receive anything of monetary value and will require students to purchase such works.

d) Public Office: plan to be a candidate or hold public office.

e) Expert Witness: plan to serve as a witness or reviewing documents for a legal matter where the university, its employees or board members (in the course and scope of their university positions), UF Direct Support Organization (DSO), UF Health or UF affiliate is a party or in a medical matter.

f) Contracts with intellectual property terms that do not include the universityprovided Intellectual Property Rider.

g) Innovation Inducement Prizes if participating as an Outside Activity.

Does anything requested create an unresolvable Conflict of Interest or Conflict of Commitment?

  • IF THE REQUESTED ACTIVITY PREVENTS THE EMPLOYEE FROM FAIRLY CARRYING OUT THEIR UF JOB OR RESULTS IN PERSONAL GAIN FROM THEIR PUBLIC JOB AS A UF EMPLOYEE, THAT IS A CONFLICT OF INTEREST.
    • If you identify a potential conflict of interest, request clarifications from the discloser. If in your discussions with the employee, they can alter their activities such that you are satisfied they can fairly carry out their UF position and they are not using UF resources or their UF position for personal gain, ensure the form accurately reflects these modifications and then recommend approval of the PAR.
    • If there is not a way for the employee to alter the activity such that the conflict of interest can be resolved, deny the PAR and explain the circumstances in the reviewer box. The COI Program will then receive the PAR for review.
  • IF A DISCLOSED INTEREST PREVENTS THE EMPLOYEE FROM EFFECTIVELY CARRYING OUT THEIR UF JOB DUE TO TIME CONSTRAINTS OR OBLIGATIONS TO THE OUTSIDE ENTITY, THIS IS AN UNRESOLVABLE CONFLICT OF COMMITMENT.
    • If you identify a conflict of commitment, request clarifications from the discloser. If in your discussions with the employee, they can reduce the time or alter the activities such that you are satisfied they can successfully carry out their UF position, proceed with recommending approval once the PAR form includes the modifications.
    • If there is not a way for the employee to alter their time commitment or the activity such that the conflict of commitment can be resolved, deny the PAR and explain the circumstances in the reviewer box. The COI Program will then receive the PAR for review.