COCI Reporting
Each of the three universities and the System Offices conduct a coordinated annual disclosure and review process for conflicts of commitment and interest among its academic staff members to meet the requirements of law and of research sponsors. These processes are conducted through the University’s online reporting tool, START myDisclosures, using the Report of Non-University Activities (RNUA) and myFCOI Checklist. For more information, consult the START myDisclosures Users’ Guide.
Academic staff members have the duty to request and obtain approval from their Unit Executive Officer (UEO) prior to engaging in activities or relationships that present “actual or reasonably perceived conflicts of commitment or interest with their University responsibilities." These activities and relationships include:
- Non-University activities, appointments, and affiliations, regardless of whether or not they produce income;
- Non-University financial relationships or fiduciary roles that constitute actual or reasonably perceived conflicts of interest with regard to the academic staff member’s University appointment, with certain exceptions as outlined
- Other financial relationships or fiduciary roles, commitments, or activities of academic staff members or their immediate family that present an actual or reasonably perceived conflict of commitment or interest with regard to their University appointment.
COCI Policy
The Vice-Chancellor for Academic Affairs and Provost is responsible for the implementation of the University of Illinois Policy on Conflict of Commitment and Interest (COCI) on the UIS campus. The University’s policy rests on a foundation of laws, statutes, and regulations. This policy is periodically revised to ensure that all regulatory requirements are properly addressed. The COCI policy can be accessed at the following link:
Conflict Management
In cases where conflicts are identified, it might be possible to manage them. A Conflict Management Plan is required when the employee or their start-up company meets any of the following criteria:
- The activity requires a significant commitment of time from the employee.
- The company licenses university intellectual property of which the academic staff member is the inventor.
- The company employs university students or other university employees.
- The activity or company utilizes university resources, such as space, equipment, or computing resources.
- The activity involves the academic staff member’s unit head, the dean, or other senior management within a unit.
- The company funds sponsored research or gifts at the university.
- The company executes a facilities use or technical testing agreement with the university.
- The company subcontracts to the university from awards such as SBIR, STTR, or DARPA on which the company is prime or accepts subcontracts from awards on which the university is prime.
- It appears necessary for any other reason, for example, if the distinction between the academic staff member’s work for the university and his/her outside activity is not clear; even if university intellectual property is not being licensed.
The employee’s unit head (for the employee's primary appointment) is responsible for managing conflicts and ensuring a formal management plan is in place when necessary. The steps for developing this plan are as follows:
- A management plan template is available for use. This template should be edited with input from the employee, their unit head, and the Associate Vice Chancellor for Research & Innovation (AVCRI) or a designee from their office.
- The UIS Conflict Review Committee should review the proposed plan and provide feedback.
- Once feedback has been addressed and incorporated, the plan should be routed for signatures to the unit head, next level approver (typically a dean), the Conflict Review Committee, and the AVCRI.
- This plan should be uploaded annually to RNUAs for the duration of the employee’s involvement with the entity.
The Conflict Review Committee at UIS is comprised of two faculty members and one AP, serving staggered three-year terms, to advise the Responsible Official when COCI issues arise.
For questions regarding the Conflict of Commitment and Interest (COCI) Policy or reporting procedures including the Report of Non-University Activities (RNUA), please email coi@uis.edu or call (217) 206-8578. For more details regarding RNUA, visit our page dedicated to the myDisclosures process.