Outside Interests

The Outside Interest module in ROAMWyo seeks information in three specific categories – Conflict of Interest, Conflict of Commitment, and Foreign Affiliations and Collaborations. It’s possible to have a combination of any of the three.

• Conflict of Interest: A conflict of interest exists when an Employee has an interest that affects or provides an incentive to affect the Employee’s conduct of her or his university activities.
• Conflict of Commitment: A conflict of commitment exists when an Employee renders professional service or engages in an external activity that is not part of his/her duties to the university that interferes with the Employee’s ability to perform their obligations to the university.
• Foreign Affiliations and Collaborations. Foreign Affiliations and Collaborations include any financial interest, whether on-duty or not, received from or relationships with any foreign entity, including foreign institutions of higher education, foreign research institutions, foreign teaching hospitals or medical centers, foreign governments, or private foreign entities.

Employees shall mean any individual who is employed by the University, whether full or part-time, and includes but is not limited to staff, faculty (including tenured, tenure-track, non-tenure track, in-residence, visiting, and emeritus faculty if performing a function for the University), administration, postdoctoral fellows, and student employees.

The University’s Conflicts of Interest and Commitment Policy is applicable to all UW employees.  Conflicts of interest and commitment, either real or apparent, can erode public and internal trust, damage the University’s reputation, hurt the University financially, and in some cases, even violate the law. 

For the same reasons why it is important for staff to complete the disclosure form as outlined above.  In addition, the proper management of conflicts of interest and commitment, and foreign affiliations and collaborations are necessary to maintain the integrity of UW’s institutional research; the quality of UW’s educational programs; the viability of UW’s outreach mission, especially as it relates to information dissemination, and technology development and commercialization.

Anything of monetary value in excess of $5,000 owned or payable to an Employee.

An annual disclosure is required (1) when hired; (2) annually, and (3) within 30 days of the acquisition of a new interest that arises outside of the annual campaign timeframe.  The annual COI disclosure campaign will commence on August 1st and run through September 30^th of each calendar year.  

A research-based disclosure is required when you are listed as key personnel on a proposal

The University of Wyoming has always had a Conflict of Interest Policy as part of the Employee Handbook.  The ROAMWyo (Cayuse) system is now being used as a means to more effectively monitor and manage conflicts of interest and/or commitment. 

Individuals that may be able to view your information include the Director of Research Security and COI, the Conflict of Interest and Commitment Committee members, and your supervisory chain of command if a conflict is identified and needs a COI management plan.

A Committee appointed by the Vice President for Research and Economic Development that assists with and reviews complex conflict matters as outlined in the policy. The Committee consists of one administrator from the Research and Economic Development Division; one representative from the Office of the General Counsel; two senior faculty members appointed by the Faculty Senate Executive Committee, and one staff employee appointed by the Staff Senate Executive Committee.

Salary, Royalties, Commissions, Consulting Fees or Honoraria, any form of compensation for services.

Multiple factors are considered during the review of a COI/COC disclosure, for example:

• The value of the financial interest – financial interests with higher values may be considered higher risk.
• The scope of the relationship with an external entity – longer and closer associations may increase risk.
• The extent of the employee’s ability to make decisions on behalf of the University regarding an outside entity.
• The extent of an employee’s ability to provide private information about the University to an outside entity.
• The seriousness of possible harm that could occur if the employee’s decisions or actions were unduly influenced by the external interest.

The University has designated an institutional official to solicit and review conflict of interest disclosures, provide information and training about conflicts of interest to the University community, and to facilitate compliance with conflict of interest/commitment policies and regulations.

Disclosures with one or more “Yes” responses to the COI or COC screening questions are reviewed by the COI Designated Official. In this review, the COI Designated Official determines whether a significant financial interest, external relationship, paid travel, or foreign influence situation constitutes a potential conflict of interest or if further review is required. The COI Designated Official may seek additional information before making this determination.

If it is determined that the employee does not have a conflict of interest situation, the employee will receive an email notifying them of the determination, with a reminder to update their disclosure within 30 days of acquiring or discovering a new significant financial interest, external relationship, paid travel or student impact situation.

If the COI Designated Official determines that a potential conflict of interest situation has been disclosed, the disclosure will reviewed by the COI Committee.  If the COI Committee determines that the employee does not have a conflict of interest situation, the employee will receive an email notifying them of the determination, with a reminder to update their disclosure within 30 days of acquiring or discovering a reportable significant financial interest, external relationship, paid travel, or situation that could negatively impact a student.

If the COI Committee determines that a conflict of interest situation exists, it then recommends actions to manage or eliminate the risk.

If the COI Committee determines that the risks involved in a COI situation can be minimized to an acceptable level through management, the COI Designated Official works with the employee and others to implement a COI Management Plan, based on the COI Committee’s recommendations.

A COI Management Plan Administrator is assigned to implement the plan, monitor compliance, and submit status reports.

If students and/or other trainees are involved, a Student/Trainee Advocate will be assigned. The Student/Trainee Advocate is charged with meeting with students/trainees to review their rights as scholars and researchers and be a point of contact if the student/trainee has any concerns. The Management Plan Administrator may serve as the Student/Trainee Advocate, or another person may be assigned.

If there is a risk of bias in the design, conduct or reporting of research, an Independent Reviewer may be assigned and charged with scientific oversight. The Management Plan Administrator may serve as the Independent Reviewer, or another person may be assigned.

The Plan Administrator, Student/Trainee Advocate, Independent Reviewer, or anyone else with a COI Management Plan role must not have a financial or vested interest in the external entity and must not be subordinate to the employee or anyone else with a financial interest in the entity. 

The COI Management Plan must be approved and signed by the employee, the employee’s department chair or director, dean or vice president, the COI Designated Official, the Associate Vice President for Research Administration, the Vice President for Research and Innovation, everyone assigned an oversight role on the plan, and, in some situations, the President of the University. In some situations, a modified COI Management Plan that has fewer management elements may be implemented. In these situations, fewer signatories may be assigned.

Elements of a COI Management Plan

The elements in a COI Management Plan vary depending on the nature of the situation and can involve:

• Requirements to disclose the conflict of interest as necessary.
• Requirements about the use of University resources.
• Information about invention disclosures and intellectual property rights.
• Requirements regarding the involvement of students.
• Mechanisms to reduce, eliminate or manage the risk of bias in the design, conduct or reporting of research.
• Supervisory changes that may be required if more than one person in a department has the same conflict of interest.
• Requirements for the approval of contracts with and invoices from the external entity.
• Requirement for the employee to recuse themselves from University deliberations, decisions, and negotiations regarding the external entity or person if a family relationship.
• Conflict of Interest training requirements.
• Any other conditions necessary to reduce or eliminate the risk that the employee’s external interest could unduly influence their professional responsibilities to the University.

 A copy of the signed COI Management Plan is distributed to all parties involved and an electronic copy is saved in ROAMWyo.

Yes, in fact it’s important to disclose any family members’ significant potential conflicts.  Disclosure is required by Federal law and the University’s Conflicts of Interest and Commitment Policy.

Family is defined as legal spouse, domestic partner, dependent children, including their spouses, and dependent relatives, including their spouses, of the Employee.

The SAP is located here.