Have a question that’s not on this list? Email us at UF-COI@ufl.edu!
What is a conflict of interest?
Under UF Policy, a conflict of interest is defined as a Private Interest, or relationship to a relative, that would reasonably appear to (a) adversely influence an Employee’s actions, judgment or decisions, required to carry out Inside Activities or (b) create an unlawful conflict with the Employee’s position as a public employee, as decreed by state or federal law, which includes a situation in which regard for a Private Interest leads to disregard of a public duty or interest.
What are outside activities?
Outside activities generally draw upon the knowledge, skills, or abilities employees use to fulfill institutional responsibilities and are performed for outside entities. Examples include consulting, teaching appointments at other universities, expert witness services, industry advisory board participation, etc.
What is a conflict of commitment?
Under UF policy, a conflict of commitment involves outside activities whose time of occurrence or duration would hinder the Employee from carrying out Inside Activities.
Who needs to complete the UFOLIO form?
Currently, UFOLIO is available for four populations: 1) Faculty, adjuncts, and postdoctoral associates holding a 0.26 FTE or higher appointment, 2) Managerial staff in Job Structure Categories 10, 11, 12, and 13 (full list of applicable job codes/titles can be found here), 3) College of Medicine TEAMS Physicians in the Regional Physician Network, and 4) Anyone who is listed in UFIRST as Key Personnel who ALSO has an active UF job record of any type (this may include employees who only hold a courtesy job record). If you are in these populations, you can access UFOLIO and submit your Disclosure of Interest (DOI) at ufolio.compliance.ufl.edu.
I am not in the current UFOLIO population. How do I disclose my outside activities and interests?
The COI Program released a new and improved PDF disclosure form in November 2022. If you do not have access to disclose in UFOLIO, please use the PDF form found here: https://coi.ufl.edu/wordpress/files/2022/10/UF-Non-UFOLIO-Disclosure-of-Outside-Activities-and-Interests-Form.pdf
How often am I expected to report my activities?
You are required to obtain prior approval for reportable outside activities and interests; please submit disclosures for outside activities at least 30 days before the anticipated start date. Your UFOLIO portfolio should be updated annually at a minimum based on the date of last approval, but must be an accurate reflection of your outside activities and interests at all times.
What types of activities and financial interests need to be reported?
Twelve types of disclosures are required under UF’s Policy on Conflicts of Commitment and Conflicts of Interest; full descriptions can also be found in the policy: https://hub.policy.ufl.edu/s/article/Conflicts-of-Commitment-and-Conflicts-of-Interest. UFOLIO provides a description of each type of disclosure that needs to be submitted, and a list of disclosure types with examples and exceptions may be found here. A useful list of examples of inside activities, as well as reportable and non-reportable outside activities and financial interests may be found here.
What if I submit a UFOLIO form in error?
UFOLIO allows for revisions; if you submitted a disclosure in error, simply select “Withdraw” on the left menu bar of the disclosure to remove the disclosure from the review process. You can then edit the disclosure as necessary and resubmit when ready.
Who will review my form?
If you disclose in UFOLIO, your information will be reviewed by designated UF administrators which at a minimum will include your supervisor and Conflicts of Interest Program staff. Additional review may be performed by your department chair, your dean/director or her/his designee, or other designees as identified by college leadership. Other ancillary UF reviewers (General Counsel’s Office, Self-Insurance Program, Office of Research, etc.) may need to review your disclosure based on the activity and/or interest disclosed. See this resource for more information about UFOLIO ancillary reviews.
For employees disclosing via the new PDF form, your disclosure will at a minimum be reviewed by your immediate supervisor and a higher-level authority/supervisor determined by your college/unit leadership. Certain types of disclosures must also be reviewed by the UF Self-Insurance Program and/or the COI Program.
Can I have someone else submit disclosures on my behalf?
No. Disclosing outside activities and interests is a personal responsibility under UF policy and state and federal law. Because these types of disclosures are for activities and interests that are not part of your UF job, it is not appropriate to delegate this task to others.
What should I do if I have an approved disclosure but the disclosed activity is completely over?
No action is required; the disclosure will automatically expire one year after the approval date.
I received an email from UFOLIO telling me that my disclosure is going to expire, but the activity/interest is over. Do I need to renew my disclosure to report that the activity/interest is complete?
No; you should only renew a disclosure if the disclosed activity/interest is continuing. Once the activity/interest is completely over, there is no need to renew your disclosure.
I am an Emeritus Professor with no active role at the University of Florida, do I need to disclose?
I am an Emeritus Professor and I also have an OPS appointment at the University of Florida, do I need to disclose?
Yes. You are required to disclose per the University of Florida’s Policy of Conflicts of Commitment and Conflicts of Interest.
I am an Emeritus Professor and I am listed as “key personnel” on a federally-funded project or proposal, do I need to disclose?
Yes. You need to disclose per the University of Florida’s Policy of Conflicts of Commitment and Conflicts of Interest and you need to answer the Conflict of Interest question in UFIRST.
I only hold a courtesy faculty position at the University of Florida. Why I am getting notices that I need to disclose in UFOLIO?
The only time someone who ONLY holds a courtesy faculty position at UF is required to disclose in UFOLIO is if they are listed as Key Personnel on research in UFIRST. If you are no longer involved at all in any UF research, please contact the COI Program at UFOLIOemail@example.com.
My disclosure is routing to the wrong supervisor for Level 1 Review in UFOLIO, how can this be fixed?
You (the discloser) and the incorrect supervisor are both able to re-route an individual disclosure to the correct supervisor by using the “Reassign Level 1 Reviewer” link on the disclosure’s left sidebar. The new Level 1 Reviewer will have to confirm that they are the correct supervisory reviewer before the reassignment is finalized. However, UFOLIO automatically routes your disclosures to the person who is listed as your supervisor in UF’s job records. To permanently ensure future disclosures are routed to your correct supervisor, reach out to your unit HR staff to request they update your supervisor in UF’s job records.
I am a 9- or 10-month employee who will be performing an outside activity entirely while I am on summer break from UF. Do I still have to disclose the activity?
Yes. Under UF Policy and Article 26 of the UF-UFF Collective Bargaining Agreement, activities undertaken entirely during a time when an employee has no Inside Activities (e.g. while an employee is on summer work break with no summer appointment) can still constitute a Conflict of Interest and must be disclosed.
How do I know if a staff member should be disclosing in UFOLIO?
Staff whose job codes are part of Job Structure Categories 10, 11, 12, and 13 are required to disclose in UFOLIO. This list contains all staff job codes in JSCs 10, 11, 12, and 13 as of September 2021.
I am filling out the new PDF form and I’m not sure who the second reviewer should be. What should I do?
Each college or administrative unit determines the second reviewer for their employees; please reach out to your unit leadership to determine who the reviewer should be. The second-level reviewer must be at a higher level than the immediate supervisor.
I am attempting to submit a disclosure in UFOLIO, but the system tells me I have no Level 1 Reviewer (supervisor) assigned. When I attempt to Reassign the Level 1 Review to my supervisor, they do not appear in the available list of people. What should I do?
Please reach out directly to the COI Program at UF-COI@ufl.edu; the situation may require a manual override.
FAQs specifically for Supervisors/Level 1 Reviewer:
I am reviewing an outside activity disclosure for one of my direct reports. How much of a time commitment for an outside activity is too high?
For full-time employees, outside activity time commitments of greater than 8 hours per week should be scrutinized carefully by supervisors to ensure the employee’s UF duties will not be negatively affected. If you have any concerns about the disclosed time commitment, please feel free to reach out to our office at UF-COI@ufl.edu.
I am reviewing a disclosure for one of my direct reports and I have concerns about the disclosed activity or interest. What should I do?
If your concerns could be addressed by getting additional information from the discloser, use the “Request Clarifications” activity on the left sidebar of the disclosure to route it back to your employee so they can make changes or provide additional information. If you have other concerns, please reach out to our office at UF-COI@ufl.edu.
A disclosure in UFOLIO was reassigned to me for Level 1 Review, but the employee isn’t my direct report. What should I do?
When a disclosure is reassigned to you, you have to either confirm or deny that you’re the correct reviewer. Select “Confirm or Deny Level 1 Reassignment” from the left sidebar, then select “No.” The disclosure will then route back to the previously assigned supervisor.
The disclosure I’ve received for review in UFOLIO is incomplete and I don’t fully understand it. What should I do?
Use the “Request Clarifications” activity on the left sidebar to send the disclosure back to the employee to ask them to make updates or provide more information.
My employee has disclosed something in UFOLIO that’s definitely part of their UF job. Should I disapprove it?
No; please only disapprove disclosures if you believe the disclosed activity or interest is impermissible according to the Level 1 Review Checklist. Instead, on the left sidebar, select “Discard as Inside Activity.” You’ll receive a popup and will need to add comments, but once you have discarded the disclosure as an inside activity (e.g. a UF activity) it will be removed from the review process.