Conflict of interest supervisor responsibilities

What is a supervisor, chair, or other manager’s responsible for in the CERT program?

• Completing an e-CERT disclosure form 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 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.

eCERT disclosure status database

Supervisors login here to determine which of your employees are not current on their eCERT disclosures.

Supervisors’ responsibilities to check for eCERT completed statuses and conduct following ups:

• Log in by clicking on the link above, at least every 30 days, to review the statuses of eCERT disclosures by the employees who report directly to you to determine who has not completed their eCERTs.
• Remind your employees to keep their eCERTs current. eCERT disclosures are required to be completed or updated by all employees within 30 days of their hire date, on an annual basis, or within 15 days of when their circumstances change, which can include but not limited to NAU relationships, outside employment or sponsored projects that affect the accuracy of their previous disclosures. Employees who are not current will continue to receive the biweekly email reminders and if the employees are not responsive within a few weeks of the notice, the supervisor must conduct a follow up.
• To accurately pull or filter the report for all employees who report directly to you, please type “your name” in the SEARCH box.
• Deans, department heads and vice presidents are encouraged to periodically check the overall completion status of other units within their reporting scope for any significant outstanding issues (such as someone that has Never Completed the eCERT and has worked at NAU for a while, or a significant number of employees Expired or Never Completed within a unit).
• To sort the data to your specifications, use the column headings, the search box, or look for specific information on the report. You will automatically see all statuses with this color-coding: Current – green, Expired – yellow, and Never Completed – pink. You can narrow what is displayed by typing in the key word such as Expired or Never Completed in the search field to see only those that need follow up. Please pay particular attention to those that have expired greater than 30 days or those that indicate never completed and are not recent hires.
• The excel function button will allow you to export the same data showing to a spreadsheet format. This is the format you would use to send to an administrative staff person or other supervisor (if needed, for follow up). Only supervisors that have employees reporting to them in the “Reports To” table in PeopleSoft will be able to view information in the database and then only the data of those employees reporting directly to them or to another supervisor that reports within their scope of reporting will show.

eCERT supervisor follow up database

This database is provided for leaders to access the eCERT disclosure information provided by their employees that disclosed “yes” to any one of these questions: Outside Employment, Public Office/Board Membership or Textbooks.  Login here to determine which of your employees need documented conflict management plans.

Supervisor responsibilities for follow up:

Log in at the link above periodically, but at least every 30 days to review the disclosures made by employees that report directly to you, found on the “needs review” tab.

• Review the data for the faculty or staff that report directly to you, and make a determination as to whether a conflict of interest exists or may have the potential to occur.
• Ensure that a conversation occurs to gather more information, if needed, and discuss how to manage, avoid or eliminate any real or potential conflict of interest.
• Document the conflict management plan within the eCert Supervisor Follow-up database, if one is needed. Instructions are provided within the database.
• Conduct second level manager reviews to ensure employees are current on disclosures and that supervisors reporting to you have completed the conflict management plans with employees and that decisions made during that process are appropriate. Click here for eCERT Second Level Manager Review Instructions.

Conflict management plan

What is a conflict management plan?

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.