Conflict of interest FAQ’s
What is the intent of the University’s CERT program? Accordion Closed
This program was developed to assist employees and the University in meeting legal and ethical standards. It is critical that all dealings be handled with the highest of standards as a way to assure the public we serve that we are managing our resources in a way that reflects positively on us as university and community citizens. As such, the integrity of all university work and service, including teaching, research, scholarly activity, and business or financial matters, must not be compromised.
How often do I need to complete the eCERT (employee conflict of interest disclosure)? Accordion Closed
A conflict of interest disclosure is required:
- Within 30 days of being newly hired at the university
- Annually for all faculty and staff
- Within 15 days when circumstances for an employee changes (such as a relationship) where the disclosure needs to be updated for accuracy
How do I report a potential conflict of interest? Accordion Closed
Go to the eCERT disclosure form to enter or update this information. This is an automated tool that will walk you through the employee disclosure that is required. You may also want to talk with your supervisor or someone in your management reporting chain about this conflict or contact one of the key resource offices listed on the main page of this website.
Why do I need to complete the eCERT disclosure? Accordion Closed
The University is obligated by federal and state laws and regulation, to identify, manage, reduce, and if possible eliminate any potential conflict of interest.
Why do I need to include information on family members? Accordion Closed
Close relationships (such as relatives or domestic partnerships) with other NAU employees or students have the potential to create situations in your work or service where the best interest of the University may conflict with (or be perceived to conflict) with your personal interests. Therefore it is required that you disclose the required information about these relationships so that a conflict management plan can be implemented (if one is needed) or action taken to prevent such conflicts of interest.
The federal and state regulations that govern objectivity in research require disclosure of financial interest including those of your spouse or domestic partner and/or dependent children.
When do I need to complete the eCERT disclosure? Accordion Closed
The eCERT disclosure must be completed at the time of hire, when a potential conflict arises, and annually.
Do I have to report changes in my activity and/or interests before the next submission date? Accordion Closed
Any changes in the status of an existing conflict of interest disclosure should be disclosed immediately and a new online submission completed.
Do students need to complete the eCERT (employee disclosure)? Accordion Closed
All employees, including student workers and graduate assistants for NAU must also complete the eCERT disclosure. A student who has no employment or specific research role (as described below) should not complete the disclosure.
If a student’s role in the study includes being a PI, co-investigator, or other senior/key personnel then they must complete an eCERT disclosure. Individuals who are responsible for designing, conducting, or reporting on a sponsored project or a proposal are collectively referred to as Senior/Key Personnel or Investigators. This includes the Principal Investigator/Project Director or co-investigator/co-director on a particular proposal, and may include postdoctoral associates, senior scientists, graduate students, and collaborators or consultants depending on their roles.
How do I determine if a financial interest requires reporting? Accordion Closed
The eCERT disclosure will provide the details you need to determine whether your situation meets the criteria for disclosing. Additionally, policies found on the CERT website related to purchasing and research (if applicable to you) may also explain these requirements. If you cannot find the information you need, please go to the Key Resource Office link on the right menu bar of this site.
What will happen if I fail to report or disclose a conflict of interest? Accordion Closed
As with any violation of University or Arizona Board of Regents policy or state statute, all employees are subject to disciplinary actions, up to and including termination for the most serious offenses. Some very specific penalties apply under Arizona statutes which pertain to purchasing, contracting, or receiving financial benefit as a result of one’s state employment. Knowingly violating some state conflict of interest laws are considered a class 6 felony. A listing of related policies and statutes can be found in the Related Policies section of the CERT website.
What is a conflict management plan? Accordion Closed
A conflict management plan may include any of the following:
- Avoiding certain types of activities. There will be some circumstances when it is necessary for an employee of the university to cease certain activities (external or internal) in order to reduce the risk of conflict of interest in their NAU position.
- Minimize the risk of a potential conflict of interest by establishing an arrangement that is agreed upon by the management chain, key resources offices, and/or university counsel that helps the institution avoid and/or properly manage the potential conflict.
- Disclosing certain relationships or outside interests to NAU. In some cases additional actions may be required beyond disclosure, but not always.
Conflict management plans should be discussed between the employee with the real or potential conflict and their supervisor/chair/manager. Discussion and agreements to manage or avoid the conflict of interest or cease certain activities should be documented and retained by the supervisor or a member of the management reporting chain. The supervisor or manager should also monitor the situation to ensure that the agreement is being followed. Conflict management plans may also need to be shared with certain key offices (HR, Legal, Affirmative Action, Research) depending on the nature of the situation.
What is a supervisor, chair, or other manager’s responsibility in the CERT program? Accordion Closed
- Completing an eCERT for their employment situation in accordance with the requirements.
- Become knowledgeable about the program using the resources provided, tutorial, quiz, website, examples, FAQ’s, etc.
- Participating in discussions with their employees who reveal a real or potential conflict of interest.
- Assist employees in finding answers to their questions about how to comply.
- Discussion should include what to avoid, how to modify situations to avoid conflicts of interest, or whether another type of remedy is warranted.
- Contacting a key resource office (left menu bar of the CERT website) to discuss how to handle a situation disclosed by the employee if you are uncertain.
- Documenting the discussion and agreement of a specific conflict management plan. The documentation should include a date of discussion, names of parties to the discussion, how the conflict of interest (or potential of) will be managed, eliminated or avoided. Share a copy with the employee and retain a copy in the employee’s departmental file.
- Follow up or monitor situations that require a conflict management plan as appropriate. Bring issues of concern to another manager in your management reporting chain OR contact the appropriate key resource office for assistance.
- Report anything you are not comfortable with until you are satisfied that the situation has been handled correctly.
Who do I call for more information? Accordion Closed
The offices listed in the top right menu on this page under “Key Resource Offices” can provide additional information on this topic.
Do all PI(s) and Co-PI(s) need to complete the eCERT disclosure annually? Accordion Closed
Yes. The PI, Co-PI(s) and all investigators must complete the eCERT disclosure annually. The term investigator refers to any individual (including but not limited to employees and students) acting for or on behalf of the University, who is responsible for the design, conduct, or reporting of sponsored activities.
I work on a sponsored project, do I have to complete the sponsored project disclosure? Accordion Closed
Maybe. Consider your actual role on the project: Are you responsible for designing, conducting, or reporting on a sponsored project or a proposal? If so, the answer is YES.
Individuals with these responsibilities are collectively referred to as Senior/Key Personnel or Investigators, and include the Principal Investigator/Project Director or co-investigator/co-director on a particular proposal, and may include postdoctoral associates, senior scientists, graduate students, and collaborators or consultants depending on their roles.
If your job responsibilities do include those listed above, you will need to disclose your and your family’s significant financial interests. That disclosure allows the University to make an informed judgment about whether the financial interest is such that it may affect how a sponsored project is designed, conducted, and reported. If that’s the case, the University will work with you to develop a plan that assures that the project will be free from bias or personal gain resulting from the conflict of interest.