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Frequently Asked Questions

Frequently Asked Questions

WHAT IS A CONFLICT OF INTEREST OR COMMITMENT AND WHO MUST DISCLOSE?

What is a conflict of interest (COI)?

A conflict of interest is any situation or relationship (personal, professional, or financial) that may compromise or appear to compromise an employee’s professional judgment in carrying out their institutional responsibilities because of an external relationship/interest of the employee or their family members. Conflicts of interest include situations that:

      • may influence or appear to influence an individual’s decision or behavior with respect to teaching, personnel actions (hiring, supervising, promoting, etc.), uses of University resources, and other administration and research matters
      • may bias or appear to bias the direction or outcomes of scholarly activities and research
      • result in a gain (personal, professional, or financial) to the individual or their family

What is a conflict of commitment (COC)?

A conflict of commitment exists when an employee’s outside activities interfere, or appear to interfere with the individual’s Institutional Responsibilities. This includes any outside services, dual employment, consulting or other activity, regardless of the location of those activities (on or off campus), the type of entity (for-profit, not-for-profit, or government), or the level of compensation (compensated or unpaid).  

Examples:

      • Holding outside (non-University) employment or entering into an agreement or arrangement to perform duties similar to university responsibilities, whether another educational institution, organization, government agency, foundation, or any entity outside of the University
      • Excessive personal consulting or related services
      • Founding a company and regularly participating in its operations during normal business hours
      • Working a secondary job that impacts your ability to perform your Institutional Responsibilities

What "family members" are included?

“Family members” include any person with whom an employee has a familial or guardianship relationship, including a parent, guardian, step-parent, child, step-child, son-in-law or daughter-in-law, brother, sister, spouse, aunt, uncle, niece, nephew, first-cousin, grandparent, grandchild, brother-in-law or sister-in-law, or any persons living in the same household.

When do I have to disclose?

Disclosures are required within the first thirty (30) days of employment, and then annually between September 1st and  October 1st, and within 30 days of any material change to your circumstance.

Are all external interests automatically a conflict of interest?

No. External interests are not automatically considered a conflict of interest. The University recognizes that external activities consistent with the professional expertise of employees can enhance one’s professional development and enhance the academic experiences of the institution’s students. However, employees owe their professional allegiance to the University. Please refer to What to Disclose for examples.

Do I have to report financial interests and outside employment during the summer months?

Maybe. Certain financial interests must be reported that exceed $5,000 or 5% ownership interest over a 12-month period. Refer to Section 3.11 Significant Financial Interest, Conflict of Interest and Commitment Policy. Because all financial interests are reportable over a 12-month period, therefore, even interests earned in off-contract periods must be disclosed.

Outside employment, including consulting, undertaken during the summer should be reported if you are performing work that is paid by Boise State University during the off-contract (summer) period.

I founded a company and anticipate doing business later. I currently have no products, no employees, nothing. Do I still have to disclose?

Yes. The definition of Significant Financial Interest includes ANY equity/ownership interest in a privately‐held company. Therefore, any ownership interest in any legal entity including single-member LLCs, is reportable even if, at this point, the entity exists mainly on paper and has no assets.

Can faculty use University resources for their outside activities?

No. Outside activities may not involve the use of University facilities, materials, services, personnel, or information without prior University approval and a written agreement between all parties.

My supervisor said that my outside activity is okay and they approve of it. Do I still need to submit a disclosure?

Yes. All employees must complete a disclosure. Please refer to Examples of Disclosable COI/Cs.

How long does the disclosure and approval process take?

The process will vary based on each individual situation.

What is a management plan?

It is a document that outlines and implements measures to actively reduce, mitigate or eliminate an actual, potential, or perceived conflict of interest held by an employee.

If I have a conflict of interest, can I still take part in the activity?

No. You should not take part in the activity until the conflict has been disclosed and addressed, including the development of a Management Plan if necessary.

I work on a sponsored project and the new Conflict of Interest Guidance requires disclosure of information that I didn’t previously have to report. Why do I have to disclose all of this?

Federal scrutiny of conflict of interest and commitment has increased greatly in the past several years.  Policies and regulation are fluid, complex, and nuanced based on situations. Expanded regulations and additional federal scrutiny require more attention on the disclosure process.

Am I prohibited from entering into an outside interest with a foreign entity?

No. Outside interests and collaborations are encouraged; however, those interests need to be reviewed and approved prior to entering into any agreements. While no affiliations are prohibited, employees must keep in mind if they plan to apply for sponsored project funding, certain foreign affiliations may not be allowable under the terms and conditions of the funding agent.

Will the content of my disclosure form be kept confidential?

Your disclosure will be maintained in confidence as far as possible. The information you submit will not be shared except with those who have a need to know. In addition to Boise State University employees with a need to know, disclosure may be made to the government or other entity, to the extent required by law or court order.

The disclosure form doesn’t ask the right questions about my situation. What should I do?

The final question asks: Do you feel that you have any potential conflict of interest or conflict of commitment issues other than those disclosed in the previous questions, or do you have any comments you would like to make? Please use this section to enter other information. When in doubt, disclosure is the best choice.

RESEARCH AND CONFLICTS OF INTEREST

Does my disclosure satisfy reporting requirements for grants, contracts, or other funding applications for federal or other agencies?

No. This disclosure process is used to report information to Boise State University. It does not satisfy any requirement to disclose information about your outside relationships and activities in grant, contract or other funding applications to federal or other funding agencies. You must still disclose any required information on all funding applications as required by the sponsoring agency.

Am I required to submit the Annual Questionnaire if I am not currently conducting research or if I do not have any financial interests to report?

Yes. All individuals covered by the policy are required to complete the Annual Questionnaire.

Do I need to disclose the salary paid to me by the university as an investigator?

Yes. All individuals covered by the policy are required to complete the Annual Questionnaire.