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New policy on consulting approved by Board of Trustees

by Karen A. Grava - April 23, 2007

Most state employees are either prohibited or discouraged from developing professional interactions with private entities.

Not UConn faculty.

They are encouraged to consult, collaborate on research projects with the private sector, and work with government organizations at the federal, state, and local levels, such as the Department of Environmental Protection or the National Science Foundation.

Faculty also share their knowledge through publishing and public speaking.

But to help faculty members avoid any appearance of conflict of interest, the University has developed new policies on consulting and conflict of interest that clarify oversight for faculty activities and require annual reporting, both at the Storrs-based programs and at the Health Center.

The policies, recently approved by the Board of Trustees, replace separate policies for the Health Center and the Storrs-based programs, and establish a centralized, electronic database on consulting activities.

The policies exercise transparency through the disclosure of an intended consulting or research engagement, good management through the University’s review and approval prior to the engagement, and oversight through the compliance audit.

“These policies are critically important to ensuring that UConn’s activities are transparent,” says Peter J. Nicholls, vice president and provost.

“Consulting and research relationships are a time-honored and common activity of faculty throughout the United States. While these activities are beneficial to both the faculty member and the corporate or government partner, these relationships have come under increasing attention, as compliance with state ethics rules has received greater scrutiny.”

The policies, developed under the supervision of Nicholls and Dr. Peter J. Deckers, executive vice president for health affairs, provide clear guidelines, which note that while consulting and outside activities are important, faculty must not use “time due the University” for consulting activities, and must receive permission for consulting each year in advance from their supervisor and the provost or the executive vice president for health affairs, before participating in the activities.

Under the new policy, they must also file an activities report at the end of the year.

Compliance with the University’s policies will be subject to a semi-annual audit by the University’s Office of Audit, Compliance, and Ethics, and an annual report will be submitted to the Joint Audit and Compliance Committee of the Board of Trustees.

“In order for UConn to maintain public trust and support in carrying out our mission, we must demonstrate to the state and federal governments that we have the highest standards of ethical behavior,” says Deckers.

“Maintaining a central repository will help us document the substantial contributions our faculty make, and simultaneously demonstrate our compliance with the standards set by University policy, federal regulations, and ethics laws.”

Consulting, defined as an activity performed by a faculty member for compensation as a result of his or her expertise, has increased markedly in the past decade, as the state and federal governments have encouraged faculty to help commercialize research and technology transfer critical to Connecticut’s long-term economic growth.

So, too, have state and federal regulations dealing with avoiding and managing potential and existing conflicts of interest.

The new policy requires faculty to file forms annually.

The forms must be signed by the department head and dean, before being submitted to either the provost or the executive vice president.

Questions about activities will be handled by a Conflict of Interest Management Committee appointed annually by the executive vice president for health affairs for the Health Center and by the provost.

“The University encourages investigators to engage in appropriate outside relationships,” says Nicholls.

“But members of the University community are expected to avoid conflicts of interest that have the potential to directly and significantly affect the University’s interests, compromise objectivity in carrying out University responsibilities, or otherwise compromise performance of University responsibilities, unless such conflicts are disclosed, reviewed, and managed.”

Information about the policy and the forms due annually by July 1 are available at http://www.osp.uconn.edu or at http://www.compliance.uconn.edu/

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