Supervisors must complete the following steps upon receipt of a COI Superform signature page from an employee.
All Faculty/Researcher COI Forms ("Regular" and PHS-Funded Versions)
Chairpersons and Directors
- Ensure that all personnel under your supervision have completed COI disclosure forms and have submitted to you a Signature Page by April 15, or if April 15 falls on a weekend or holiday, the immediately following work day.
- Review all printed Signature Pages from employees.
- Complete a Management Reporting Form (MRF) for each employee that disclosed outside interests. On this MRF, identify any COIs and explain how your department is managing them. The same MRF is used for both the "regular" and PHS-Funded Faculty/Researcher COI forms.
- Once all Signature Pages are collected, complete an Annual Data Summary Report for University Faculty/Researcher COI Forms.
- Submit to your Dean or Regional Campus President and/or retain the following documents:
- Submit all Signature Pages that report one or more outside financial interest(s).
- Retain all Signature Pages that do not report outside financial interests in your unit for seven (7) years.
- Submit all signed MRFs.
- Submit the department's Annual Data Summary Report for University Faculty/Researcher COI Forms.
Deans and Regional Campus Presidents
- Review forms received from chairpersons and/or directors. Approve or modify any MRFs as necessary.
- Prepare your unit's (e.g., school or regional campus) Annual Data Summary Report for University Faculty/Researcher COI Forms.
- Submit all Annual Data Summary Reports, Signature Pages, and MRFs received from all departments in your unit, as well as your own unit's Annual Data Summary Report for University Faculty/Researcher COI Forms, to the Provost or Senior Vice Chancellor for the Health Sciences.
- All documentation is due by May 15.
Designated Administrator/Staff COI Form
- Ensure that all those who are required to complete this form have submitted a Signature Page by April 15.
- Review printed Signature Pages received from employees.
- Develop a COI Management Plan to address any conflicts disclosed. Document the plan and the employee's agreement to it in the form of a memorandum. Do not use the MRF referenced above, the MRF is only to be used for the Faculty/Researcher COI forms.
- Retain a copy of this memorandum within your unit. The memorandum does not need to be forwarded to the next higher supervisor unless he or she requests it.
- Complete and submit the Annual Data Summary Report for Designated Administrator/Staff COI Forms to the next higher reporting authority within your responsibility center, listing the number of disclosures submitted and the number that disclosed outside interests or activities. This form is due by May 15.
- Unresolved conflicts must be reported to the provost, senior vice chancellor for the health sciences, or executive vice chancellor by May 15.