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Instructions For Annual Certification Renewal

Upon receipt of letter from the Vice Chancellor requesting COI annual disclosure:

1. Send out a memo to all unit EPA employees, copying the cognizant Dean or Vice Chancellor’s office, that contains the following minimum elements:
   1. Request completion of the web-based COI forms by all EPA employees.
   2. Clearly define who is an EPA employee.
   3. Define all relevant circumstances that constitute a real or perceived conflict of interest subject to disclosure.
   4. Highlight that a change of status (a conflict or new relationship comes into being after the annual renewal period) during the year necessitates an updated COI disclosure form.
2. At the COI web page main screen, you may check for covered employees who have completed their disclosure form along with ones who have yet to complete their disclosure form.  Follow-up is key to capturing all covered employees’ disclosures.
3. Department heads must review each form for completeness and if warranted, determine if a management plan has been sufficiently developed.  Approvals will be handled electronically and automatically forwarded to the next level approver, as applicable, with the management plan incorporated into the disclosure.
4. Set an internal deadline date that Department Heads must certify to your College/Division personnel.
5. If all responses on the disclosure form are NO, then the disclosure form will be retained in the departmental/unit electronic files.  These electronic files are to be considered part of an employee’s personnel record.
6. If any response on the disclosure form is YES, then the department head and the disclosing party discuss and agree upon a management plan, which is developed from answers provided in the disclosure form itself.
7. Colleges and Vice Chancellor’s offices must submit their certification to Research Administration via email from Dean/Vice Chancellor no later than September 15, 2005.
8. Provide periodic reminders to all covered employees reminding them to update their disclosure form as circumstances change.

 

Who Is An EPA Employee?

1. Any EPA Professional, without Academic Rank, who receives pay
2. Any Faculty member (e.g. full professor, assistant professor, adjunct, emeritus) who receives pay
3. Post Docs
4. EPA Temps
5. Instructors/Lecturers, including part-time
6. Visiting Faculty