Conflict of Commitment and
Outside Activities
Internal Audit Report No. I2016-110
October 28, 2016

Prepared By
Julie Chung, Senior Auditor
Reviewed By
Loran Lerma, Principal Auditor
Reviewed By
Niran Joshi, Associate Director
Approved By
Mike Bathke, Director

 UNIVERSITY OF CALIFORNIA, IRVINE
BERKELEY • DAVIS • IRVINE • LOS ANGELES • MERCED • RIVERSIDE • SAN DIEGO • SAN FRANCISCO

SANTA BARBARA • SANTA CRUZ

INTERNAL AUDIT SERVICES
IRVINE, CALIFORNIA 92697-3625

October 28, 2016

JOAN TENMA
ASSISTANT VICE CHANCELLOR
OFFICE OF ACADEMIC PERSONNEL
RE: Conflict of Commitment and Outside Activities Audit
No. I2016-110
Internal Audit Services has completed the Conflict of Commitment and Outside
Activities review and the final report is attached.
We extend our gratitude and appreciation to all personnel with whom we had contact
while conducting our review. If you have any questions or require additional assistance,
please do not hesitate to contact me.

Mike Bathke
Director
UC Irvine Internal Audit Services
Attachment
C: Audit Committee
Diane K. O'Dowd, Vice Provost, Office of Academic Personnel

 Conflict of Commitment & Outside Activities

I.

Report I2016-110

MANAGEMENT SUMMARY
In accordance with the fiscal year 2015-2016 audit plan, Internal Audit Services
(IAS) conducted a compliance review of Academic Personnel Manual - 025 & 671
(APM-025) and (APM 671) on Conflict of Commitment and Outside Activities of
Faculty Members at the University of California, Irvine (UCI). In general, the
review disclosed internal control/compliance weaknesses that should be improved
to minimize risks and ensure compliance with University policies and procedures
and/or best business practices. The following concerns were noted.
Annual Reporting – The annual COC reporting forms in four schools for the fiscal
year ending June 30, 2014 were reviewed and several compliance issues were
noted. Some faculty did not submit annual reports or submitted the reports well
after the due date. Some faculty reported they engaged in Category I activities but
had not submitted a request for Category I prior approval. In one school, the Dean
had not reviewed or signed any of the annual reports as required by policy. In
another school, the department chairs reviewed and signed their own annual
reports, and did not submit them for the Dean’s review and signature. These
observations are discussed in section V.1.
Oversight – Adequate processes are not in place to track, monitor, and maintain
the Dean’s Office Surveys submitted by each school or requests for Category I
prior approvals submitted by faculty. Further details related to these issues are
provided in section V.2.
Policy Implementation – There is inconsistency and confusion in the reporting
requirements for faculty that have appointments in different schools. Also,
although the COC-OA policy was revised, issued effective July 1, 2014, and
implemented immediately, the policy changes were not communicated to the
schools for implementation. As a result, faculty continued to use the outdated
form and did not report uncompensated outside activities as required by policy
for FY 2014-2015. These observations are discussed in section V.3.
Training – A formal training on policy requirements is not provided to the
faculty, department chairs, or staff. Only three schools discussed the general
policy requirements with faculty as part of the new employee orientation training.
This observation is discussed in section V.4.
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II.

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BACKGROUND
Outside activities, whether professional or non-professional, compensated or
uncompensated, may raise the appearance, or the reality, of a COC to the faculty
member’s University obligations.
The University of California has established specific guidelines for identifying or
categorizing, reporting, and managing such activity in a policy on COC and
outside activities of faculty members, Academic Personnel Manual - 025 (APM025) and APM 671. This policy provides guidance of outside activities in order to
avoid conflicts of commitment, ensuring that the activities performed outside the
University do not interfere in the successful performance of their duties and
responsibilities to the University.
According to the guidelines presented in APM - 025-10 and APM 671-10, faculty
are responsible for complying with this policy, including but not limited to:
1. Obtaining prior written approval for engagement in Category I activities by
completing the prior approval request form (APM-025/APM 671 APPENDIX B).
2. Disclosing all Category I and Category II activities (or the lack thereof) by
submitting a report (APM-025/APM 671 APPENDICES C & D) to the Department
Chair annually.
The mechanisms for managing a faculty member’s outside activities are presented
in APM - 025-26/APM 671-26. It states that each campus is charged with
implementing the procedures necessary to properly manage outside activities.
Department chairs are to monitor compliance with this policy by collecting and
reviewing annual reports and address any concerns if in doubt as to whether there
is a COC associated with any current or prospective outside activity. Also, deans
are responsible for reviewing department chairs annual reports of outside
activities each year.
Lastly, the Office of Academic Personnel (AP) at UCI interacts with the Office of
the President, the Chancellor, Executive Vice Chancellor, Associate Vice
Chancellor, faculty as well as the school/department academic employees to
analyze, interpret, and train in order to properly implement AP policies and
procedures.
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PURPOSE, SCOPE, AND OBJECTIVES
The objective of the audit was to evaluate whether or not UCI faculty and
management were generally in compliance with APM-025/671. The scope of the
review focused on the annual reporting for fiscal year (FY) 2013-2014.
Based on the assessed risks, the following audit objectives were established for
the schools/departments selected for further review.
1. Verify if the entire population of academic appointees subject to APM-025/671
were captured for FY 2014-2015 annual reporting.
2. Determine if annual reports were submitted in a timely manner by the due
date.
3. Determine if activities were properly categorized and reported.
4. Verify if prior written approval for engagement in Category I activity was
obtained as required by policy.
5. Verify if exceptional approval for exceeding time limits was obtained as
required by policy.
6. Determine if income exceeding threshold for School of Medicine (SOM)
faculty was properly reported.
7. Determine if faculty members, department chairs, and deans signed the
annual reports as required.
8. Determine if there is a process to review positive disclosures or disclosures
that appear to be missing based on academic appointee’s known outside
activities at the departmental level.
9. Determine if there is a secondary review or oversight by AP to ensure that
departments are in compliance with policy.
10. Determine if academic appointees and/or staff received appropriate
orientation or training on COC and outside activities.
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11. Assess and review selected information technology (IT) general controls.

IV.

CONCLUSION
Based on our review, the UCI AP Office has established processes in place to
ensure timely reporting by faculty and review by department chairs/deans.
However, IAS identified compliance issues and concerns in the areas of annual
reporting, annual report reviews, policy oversight, and training.
Observation details and recommendations were discussed with management,
who formulated action plans to address the issues. These details are presented
below.

V.

OBSERVATIONS AND MANAGEMENT ACTION PLANS
1. Annual Reporting
Background
The UC Regents’ Standing Order 103.1(b) states that faculty members shall not
allow outside employment to interfere with primary University duties.
University policy applicable to Academic Senate members is found in APM—
025 (general campus faculty) and APM-671 (Health Sciences Compensation
Plan faculty); each policy includes specific time limits for certain types of
outside activities. Whether professional or non-professional, compensated or
uncompensated, an outside activity that interferes with successful
performance of a faculty member’s University obligations represents a COC.
Faculty are responsible for complying with this policy, including:
1. Obtaining prior written approval for engagement in Category I activities;
and
2. Submitting annual reports of all Category I and Category II activities to the
Department Chair.
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UC policy mandates that faculty submit an annual report, whether or not they
are engaged in these activities (a response of yes or no is required).
Observation
IAS reviewed the annual COC reporting forms (312 total reports) for the School
of Business, School of Law, School of Engineering, and five departments in the
SOM (Surgery, Urology, Psychiatry & Human Behavior, Ophthalmology, and
Orthopaedic Surgery) for the fiscal year ending June 30, 2014 and noted the
following compliance issues.
•
•
•

•
•

•

Twenty-two faculty (7 percent) did not submit annual reports.
Four faculty reported they were engaging in Category I activities but did
not receive prior approval.
None of the School of Law reports had been reviewed or signed by the Dean
(after IAS requested the reports, the Dean reviewed and signed the reports
on February 22, 2016 – 15 months after the due date).
Eighty faculty (26 percent) either submitted reports after the due date or
did not date the report (so it’s uncertain if they were timely).
For all five SOM department chairs who submitted the annual reports, the
deans did not review and sign the forms. Four department chairs signed
their own forms and one department chair had a subordinate sign the form.
None of the School of Business reports had been dated by the Dean or
Associate Dean so it’s uncertain if they were timely.

Management Action Plan
Failure to submit report in 2013-14
 School of Law in 2014-15 continues to have faculty who are not
complying with this policy. We will follow up with the Law School
Dean to ensure compliance to this policy in 2014-15 and 2015-16.
 School of Engineering has dramatically improved faculty reporting in
2014-15, to a 98% submission rate, with only two faculty members, who
failed to submit their reports. We believe this was a direct result of the
implementation of the Dean’s survey and AP’s consistent follow up
during Fall 2015.
 In SOM, individuals listed in this observation (as not having submitted
the annual report in 2013-14) all turned in their APM 671 report for 20145

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15. We attribute this high compliance rate to the recently launched SOM
COC electronic reporting system.
 Reporting has improved for 2014-15 for the entire campus, with regard
to timeliness (87% of schools submitted reports within 2 weeks of the
deadline, with 60% submitted on time) and completeness (only 3.6% of
all faculty failed to submit reports). The Vice Provost for AP has
followed up with each dean to require that these missing reports be
submitted by December 2, 2016.
Failure to seek prior approval in 2013-14:
 School of Law: Three faculty members reported having engaged in
teaching in other educational institutions without seeking prior
approval. We will provide feedback to the School’s dean to inform
faculty members and administrators of the APM 025 prior approval for
Category I requirement for outside activities, such as teaching.
 School of Engineering: The fourth professor in question did request
prior approval for other outside activities during 2013-14 and noted in
the annual report that he sought prior approval in a leave request. The
dean’s office did not receive a prior approval form for the teaching
activity and reported that this faculty did not seek prior approval. AP
will ask the dean’s office to follow up with this faculty member with a
reminder regarding prior approval for Category I activities.
 While the observations identify areas that would benefit from the school
reaching out to get additional information, we do want to note that it is
critical to receive clarification from the faculty before making an
assumption that policy has been violated. When IAS met with AP to
discuss specific observations, IAS made an observation that schools
should have questioned some of the activities on the annual reports. AP
shared that department chairs and deans are oftentimes already familiar
with the outside professional work of their faculty or they may have
received verbal clarification when speaking to a faculty member about
a specific activity. Documentation of this follow-up is not currently
captured in our manual system.
Failure to Review by Deans 2013-14:
 As this is a dean’s delegated action, the Vice Provost for AP will send a
memo to the deans reminding them of the policy requirement with
respect to the following:
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o Faculty in the appointment titles of set out in APM 025/671 must
submit a report annually.
o Report submission must be timely, and forms must be properly
dated and signed by the faculty member, chairs and deans. We
will clarify that while a dean may have reviewed the annual
reports, a failure to sign the reports implies otherwise.
o Department chairs and deans should review the report for
compliance with respect to the category of the reported activity,
whether time limit was exceeded, and if prior approval was
sought (if required) and follow up with faculty member if any of
these were not in compliance.
Chairs Signing Their Own OPA Forms:
 Chairs should submit their OPA forms to the dean for approval. We
recently learned that SOM launched an electronic system to manage the
collection of their annual reports, so this oversight may be rectified now
within their system. It should be noted that the SOM system was
developed without consultation with AP and does not permit workflow
approval, does not categorize activities to identify them for preapproval or reporting compliance, and does not have reporting
capabilities. This system also does not track requests for approval
involving students in OPA, nor does it provide policy training or
resources within the system.
Dean’s review of OPA reports:
 The Vice Provost for AP will discuss with the Provost a possible new
requirement for deans to report their oversight of faculty compliance of
COC annual report during the annual dean’s annual performance
management process to ensure proper review and enforcement by
deans of COC compliance. In this way, compliance management will
affect the dean’s annual assessment.
2. Oversight
Background
In regard to the UCOP policy on COC and outside activities, AP has been
reviewing requests submitted by faculty for Category I activities in addition to
addressing inquiries from faculty and staff as well as sending out reminders
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about the due date to ensure timely reporting by the faculty. To further ensure
compliance to this policy, in its oversight role, AP had required additional
reporting from each school. Approximately a month after the reporting due
date for faculty (within the first week of December), each school was required
to complete the Dean’s Office Survey which summarizes the reporting statistics
for each fiscal year and submit the survey to AP for review.
As part of the AP’s written COC procedures for the Dean’s Office Survey, AP
is to:
o Acknowledge receipt immediately;
o Print one copy for paper file and ensure there is one electronic copy;
o Review for:
 Dean Signature
 Completeness
 Compliance Issues
• Have any faculty not submitted?
• Have any faculty exceeded limits or failed to request prior
approval?
o Follow up with Chief Personnel Officers (CPOs) to correct any issues that
may be corrected; and
o Send reminder emails to CPOs who have not yet submitted a Survey.
Observation
Manual paper-based processes for the completion of annual reports and Dean’s
Office Surveys are not efficient or entirely effective for ensuring compliance
with policy. The responsibility for monitoring COC and outside activities is
delegated across the campus, and consequently, processes for monitoring
activities varies.
For fiscal years (FY) 2011-2012, 2012-2013, and 2013-2014, IAS reviewed AP’s
processes and practices in place for reviewing, maintaining, and monitoring
the Dean’s Office Survey from each school. In addition, IAS reviewed AP’s
processes for reviewing, maintaining, and monitoring Category I requests. IAS
noted the following issues.
•

AP does not have an adequate process in place to track, monitor, and
maintain the Dean’s Office Surveys submitted by each school. None of
SOM Dean’s Office Surveys had been received for the last three years. In
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addition, AP did not properly maintain and file the Dean’s Office Surveys
submitted by the other schools. For FY 2011-2012, AP had maintained only
one Dean’s Office Survey on file. For FYs 2012-2013 and 2013-2014, AP had
not maintained the Dean’s Office Survey from two schools.
Since many of the surveys for the three year period reviewed were either
not received or not maintained it is uncertain how many COC reports were
completed and whether compliance issues existed (failed to request prior
approval for Category I, exceeded limits, completeness, chair and dean
review/approval/signature, etc.). IAS noted that seven SOM departments
did not have any COC reports on file for FY 2013-2014. In addition, since
AP only requests the Dean’s Office Surveys, not the actual COC forms
submitted by faculty, compliance issues go undetected.
•

AP does not have an adequate process in place to track, monitor, and
maintain Category I activities. AP maintains Category I approval requests
in an Excel spreadsheet but the listing was incomplete. IAS bounced the
Category I activities listed on Dean’s Office Surveys to the Excel
spreadsheet and noted some did not appear on the report. In addition,
some entries were incomplete so it’s uncertain if they were approved.

IAS recommends an electronic system for the collection of annual reports,
which would help to resolve many of the challenges with compliance and
provide AP with better oversight capabilities and reporting mechanisms.
Management Action Plan
Collection of annual reports has been a delegated responsibility of the dean in
each school at UCI. In response to areas of improvement identified in the 2007
internal audit, AP implemented a process by which deans must report on
faculty compliance with the requirements of APM 025/671.
The
implementation of these Dean’s Surveys provided central office oversight for
school review of outside professional activities (“OPAs”) reported by its
faculty. In AP’s review of the Dean’s Surveys, should AP require additional
information, such as individual faculty annual reports, the reports would be
requested and provided.
Due to several staff turnovers in AP since 2012, we acknowledge that the
Dean’s Surveys collected for 2011-2012 were misplaced. In addition, the
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subsequent loss of critical staff in the SOM dean’s office contributed to why AP
was not able to collect SOM Dean’s surveys for several years.
Since Fall 2015 and currently, management of the COC for OPA in APM
025/671 resides with the position of Academic Employee Relations (AER)
Analyst under the direction of the Director of Academic Employee Relations
and Faculty Development. For the annual reporting related to 2014-15, the
AER Analyst has prepared a Policy Compliance Summary that reflects analysis
of policy compliance at the school, department, and faculty levels. The analysis
includes timeliness of reporting, completion rates, faculty reporting rates,
instances when faculty exceeded the maximum number of days, and approval
of category I activities. The Vice Provost for AP will use this report to follow
up with each dean to do the following:
•

•

Require faculty who are delinquent in submitting their annual reports
to submit a 2014-15 report. Inform those not in compliance that further
non-compliance may result in a loss of privileges, including the ability
to go on a sabbatical, submit an academic personnel review file, or
participate in a salary program such as the Health Sciences
Compensation Plan or the Negotiated Salary Trial Program; and
Notify faculty who failed to submit prior approval requests for reported
Category I activities and/or exceeding time limits that a record of their
non-compliance will be maintained in their file, in lieu of the activity
approval documentation.
Additionally, a warning that future
infractions may result in a loss of privileges, as described above, will be
provided to non-compliant faculty, Chair, Dean, Provost and
Chancellor.

Creation of Electronic System to Manage Faculty COC OPA Compliance
We recognize that a manual, paper-based process for completing the annual
reports has many drawbacks and makes managing compliance of this policy
challenging. We agree that a single electronic system will provide the Vice Provost
for AP the ability to improve oversight of school policy compliance, including
meaningful timely follow-up with faculty who fail to comply with policy.
In 2010, the Associate Chancellor led a campus-wide task force to identify a
common system for conflict of interest (COI) and COC compliance needs for the
medical center, general campus and SOM. The goal of this task force was to meet
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the compliance requirements for research compliance, academic personnel policy
compliance, senior management group reporting compliance, physician reporting
compliance under the Sunshine Act, etc.
Unfortunately, campus funding
constraints and a lack of support from the system-wide compliance leaders (who
required a majority of UC campuses to sign on before committing any funding
assistance) stalled this comprehensive compliance initiative. Since then, UCI’s
Research office has moved forward with a Kuali COI system to meet its specific
COI needs; the Kuali system does not provide COC management and efforts to
add this functionality have not been successful.
AP is in the initial stage of exploring the creation of a COC-only system, possibly
with UC system-wide partners. We envision a “smart” system that can issue an
annual call to faculty and allow for direct submission and real-time entries of
activities as well as customized reporting functions to track compliance. A COC
system will prompt faculty users and initiate a process to electronically request a
Category I approval or to request exception to exceeding their OPA time limit in
real time. A “smart” system will inform faculty, at time of submission, whether
their outside professional activity falls under a category that requires prior
approval, and the system will capture the activity when entered, thus allowing the
faculty to meet their reporting obligations. In addition, training and educational
material regarding COC requirements can also be built into this system so users
can obtain clarification about the policy requirement when they are most receptive
to it – at the time they need it.
At the time of this response, funding and personnel resources needed to build such
a system are under discussion but have not been secured. While we recognize that
this COC-only system does not provide the ideal solution for faculty members –
that is, it is not a comprehensive “one stop-shop reporting” solution for faculty to
input their outside activities as had initially been discussed in 2010 – the COC-only
system will nevertheless facilitate reporting and compliance efforts for faculty and
administrators alike. Additionally, as it is envisioned, the COC-only system will
be able to share information with other systems, such as UCI Research’s Kuali COI
system. We are hopeful that we can generate interest amongst other UC AP offices
with the same need to help share the cost of developing this system. A draft
business plan for this multi-campus COC application has been developed. A
formal plan will be presented to the Council of Vice Chancellors (COVC) for
discussion this fall.

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3. Policy Implementation
Observation
IAS reviewed policies relating to COC-OA and noted the following.
•

IAS found instances where faculty had joint appointments (50 percent
appointments) in different schools and there is confusion as to how
reporting should be handled. IAS noted that some schools obtained reports
from faculty with 50 percent appointments, while other departments
assumed that the home department was responsible for obtaining reports
from faculty. Policy is not clear on how these appointments should be
handled for reporting purposes.

•

The COC-OA policy was revised, issued effective July 1, 2014, and
implemented immediately. The revised policy included several changes to
the reporting form; the most significant change required that faculty report
compensated as well as uncompensated outside activities. As of March
2016, the new form was not posted on the AP website. As a result, faculty
continued to use the outdated form and did not report uncompensated
outside activities as required by policy for FY 2014-2015.

Proper implementation of policy not only ensures compliance with policy and
procedures but minimizes the likelihood of errors or violations.
Management Action Plan
Faculty with Split Appointments (50/50)
It should be noted that while Academic Personnel Manual (APM) 025/671
requires faculty in titles subject to APM 025/671 at 50 percent or more to report
the OPA annually, it does not have specific policy language regarding
treatment of faculty with split appointments. As faculty with split
appointments between the SOM and the general campus are considered to
have reporting responsibility only in the SOM, due to their Health Sciences
Compensation Plan obligations, it is reasonable to require faculty with nonSOM split appointments to only report their OPAs in their home department
as duplication of records is not only time consuming but will lead to confusion.
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This will be clarified in the annual reporting call and campus procedures in
APP-1-15.
APM 025/671 Revision as of July 1, 2014
AP typically creates parallel campus resources for system-wide policies,
customized for campus-specific implementation. We acknowledge the
oversight that our campus form for OPA was not updated to include
uncompensated Category I and II activity reporting in a timely manner. An
updated version that is consistent with the current version of APM 025/671 has
been posted to the AP website.
Due to several unanticipated staff transitions, COC had not received consistent
oversight. As of Fall 2015, this functional oversight has been assigned to the
Director of Academic Employee Relations and Faculty Development, whose
staff had been in the process of updating the UCI campus procedures, APP 115, when this audit was initiated. The Director, in consultation with Assistant
Vice Chancellor, made a decision to hold off on updating this campus
procedure until the conclusion of the audit, so as to incorporate any suggested
improvements to the current COC process in the revised Academic Policies &
Procedures (APP) 1-15.
4. Training
Observation
IAS conducted a survey to determine if training is provided to faculty. In
addition, school/departmental staff who assist the department chairs with
obtaining, reviewing, and filing the reports were interviewed to determine if
they received training on the policy.
The survey results and interviews disclosed that although staff in each
department has a liaison in the AP office to discuss specific issues, a formal
training on policy requirements is not provided to the faculty, department
chairs, or staff. Also, the survey disclosed that only three schools discussed the
general policy requirements with faculty as part of the new employee
orientation training.

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Management Action Plan
AP was interested to learn that an IAS survey was conducted with schools
during this audit on COC-OPA practices. If IAS is willing to share the results
of this survey with AP, it would assist AP in addressing any training
deficiencies or needs identified by our schools.
In December 2012, AP partnered with the Office of Technology Alliances (now
called Applied Innovation) and Campus Counsel to provide training to
address Intellectual Property Issues in Faculty Consulting & Employment
Agreements to our business partners, the administrative officers, in the
schools. This training not only provided the basis of how, what, and when to
report outside professional activities, but also why it is important to manage
these activities. The presentation is posted on AP’s website and linked within
our campus procedures on OPA, viewable by faculty and staff.
In determining what critical training areas related to this policy should be
provided regularly to deans, faculty, chairs, and staff, we asked ourselves the
following questions:
•
•

How can we improve the reporting process for faculty to submit their
Annual report for OPA?; and
How can we make it clear to faculty that prior requests for approval are
required in the following areas related to OPA: Category I activities,
exceeding maximum time limits, exceeding income limits, and involvement
of students?

We recognize that inclusion of this critical compliance responsibility in training
is important; however, annual workshops covering the policy and reporting
procedure will likely not be as effective as “just in time” training. We believe
that an electronic system would allow not only systematic monitoring of
reporting compliance, but would also provide more effective
education/training than could be provided by in-person workshops or online
training. For example, training and educational material regarding COC
requirements can be built into this system so users may obtain clarification
about the policy requirements in “real time” while they are using this system
to log their activities – when they are most receptive to it, at multiple times
throughout the year, at their own pace, and closest to the time when they must
apply the knowledge. These benefits would all serve the broader purpose of
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reducing errors in reporting. The system will accurately categorize the
submitted activity, based on the activity type (e.g., teaching at another
institution, serving as a board member) at the time of submission. If the
activities require prior approval, the system will prompt the approval
workflow for faculty to submit a prior approval request. Finally, any activity
logged throughout the year will be automatically loaded into the faculty
member’s annual report, so that the faculty member does not need to wait until
the end of an academic year to report an entire year’s worth of activities.
The system has an added training benefit of tracking compliance discussions
in a more useful format than individual administrators’ and faculty members’
email inboxes. Should a faculty member, chair or dean have more detailed
questions about a particular activity, this consultation can be conducted within
the system using a messaging function. For example, the faculty member
would send an inquiry to Academic Personnel through the system and receive
a response. Each message would be associated with the activity under the
faculty member’s profile in the system. This kind of oversight discussion will
be invaluable to the Vice Provost for AP when reviewing for policy compliance,
and provide additional assurance to faculty that the advice they receive
regarding a complex or specific policy compliance issue is recorded within the
system. Should complex situations arise in this process of vetting the activity,
there are resources on campus, such as campus counsel, AP, and Applied
Innovation to assist. These complex discussions seldom arise in the context of
general training, but are nevertheless equally important in developing faculty
understanding regarding their compliance obligations.
Collaboration with Office of Research on COI requirements
Since Fall 2015, Academic Personnel Office has partnered with the Office of
Research to collaborate on the review of Conflict of Interest disclosures when
these disclosures touch on COC requirements, such as prior approval for cofounding a company or serving in executive/managerial roles. In addition,
Academic Personnel contributed to the contents related to COC compliance in
a handbook called, “Start-up Guide for Employee Inventors,” that is a joint
creation of the Office of Research, Applied Innovation, SOM, and AP. The
purpose of this handbook is to serve as a high-level guide and overview of
some key questions and issues, including involvement in outside professional
activities and policy requirements for prior approval for certain outside
professional activities, that faculty may face as they begin to consider starting
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a new company around innovations emanating from their research. This guide
includes a table that identifies COI and COC approval and reporting
requirements for common roles faculty members may serve when pursuing
inventions.

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