University Disclosure Requirements

Conflict of Interest/Conflict of Commitment

What is it?

The Conflict of Interest/Conflict of Commitment (“COI/COC”) disclosure is required by the COI/COC Policy.  The policy requires all faculty and staff who work at least thirty (30) hours per week (or 0.75 FTE) to disclose and get prior approval for any reportable outside activity.  The policy defines nine (9) categories of reportable outside activities:

• Management or material interest in a business entity;
• Running for or holding a public office;
• Outside teaching appointments;
• Outside research, writing or editing in your field that is not part of your University duties;
• Development of outside educational materials;
• Royalties from licensing and copyright;
• Expert witness or legal consulting;
• Professional services related to academic or professional field;
• Leadership roles in outside organizations.

These types of activities are all activities that do or may present a conflict of interest or conflict of commitment between the outside activity and the performance of the employee’s duties.  Disclosures are to be made prior to engaging in the activity and on an annual basis.  The disclosure should then be approved by a faculty member’s chair, dean, and the Provost.  A staff member’s disclosure should be approved by their supervisor and their Vice President (or equivalent).

When do I disclose?

Ideally, the initial disclosure of the activity should occur prior to your engagement with the activity so that you can secure permission to perform the activity.  Permission should be granted so long as your chair or supervisor does not have any concerns about the outside activity interfering with your work duties, there is no actual conflict of interest or any conflict can be managed, and the activity does not implicate a serious research or national security concern.  Thereafter, the activity should be reported on an annual basis; an activity can be removed from the annual report if you are no longer engaged in it.

Why must I make these disclosures?

There are several reasons the University is requiring the disclosure and approval of certain outside activities including those that do not include paid compensation.  USG policy requires USG employees to disclose and fully report any activity that has the potential to become an apparent or actual conflict of interest.  Employees are also prohibited from engaging in any conflict of commitment, which is a type of conflict of interest that interferes with the discharge of an employee’s official duties.  Each institution is permitted to adopt guidelines for the implementation of the policy.  The categories of reportable outside activities are those which have the most potential to create apparent or actual conflicts of interest.

In addition, several concerns have been raised on the national level regarding threats to research security interests that can be posed by researchers with conflicts of interest or conflicts of commitment.  While some of these threats can be characterized as violations of research integrity principles, others rise to the level of theft of intellectual property.  These concerns are documented in a report commissioned by the National Science Foundation known as the JASON Report on Fundamental Research Security, JSR-19-21 that was released by the MITRE Corporation in December 2019.  The report encourages institutions for higher education to develop robust conflict of commitment policies to manage these risks.

Many of the activities required to be disclosed by the policy are activities that, at least for faculty, probably have been disclosed in annual reports and reviews.  One function of this policy is to have those disclosures in a central location.

How do I disclose?

For Fall 2021, disclosures should be made on a .pdf form.  January 2022 disclosures will be submitted electronically by the employee for approval via the University Conflict of Interest/Conflict of Commitment Annual Disclosure form.  This form will be pre-populated by the employee’s previous disclosures until removed by the employee when the disclosure is no longer current.

To whom do I disclose?

For faculty members, the form is sent up the supervisory chain, reviewed according to approval guidelines, and signed by the discloser’s chair, dean, and the Provost.  For staff, the form is reviewed according to approval guidelines and signed by the immediate supervisor and the VPBF. 

Financial Conflict of Interest (Research)

What is it?

The Financial Conflict of Interest for Research (FCOI) disclosures are required by the University before a proposal can be submitted for sponsored or externally funded research.  The content of the disclosures is governed by federal regulations pertaining to federal grant research.  Disclosures are made through the CX sponsored research proposal submission system. Researchers are also required to maintain current FCOI training (required once every 4 years) and Responsible Conduct of Research training (once during tenure) on the CITI platform prior to submitting a sponsored research proposal. More information can be found at the FCOI website, 

What has to be disclosed?

The Research FCOI Policy requires that researchers disclose any significant financial interests that they or any member of their immediate family have in any commercial enterprise or with members of the research team that may in any way influence the proposed sponsored research program or be affected by its performance of completion.  The FCOI website contains additional information.  Research FCOIs can include activities and assets that are not required to be disclosed pursuant to the COC/COI policy including personal assets of immediate family members that may be related to research funding or funder interests. 

Why must I disclose these interests and why must I disclose them separately from my COI/COC disclosures?

The FCOI disclosures are required by federal regulations for any research sponsored by federal agencies at the specified timeframe.  The disclosures are done through the CX system, which is the workflow system utilized by the Research Services Office for sponsored activity proposal  submission.  This allows grant coordinators to review disclosures in real time.

When do I disclose?

You should make FCOI disclosures before starting any sponsored research project or being named as key personnel on a sponsored research proposal,  Disclosures should be made  annually so long as you continue to submit proposals for sponsored research.  

How do I disclose?

You will receive an email from the CX system when your proposal or award is entered into the CX system. The email will contain a direct link to your disclosure.  If you have a new event to report after the award is made, go to the FCOI website.  A link on that page will take you to the CX system or you can enter from your CX dashboard to make your disclosures.

To whom do I disclose?

These disclosures are made to the Research Services Office through the CX system.

State Business Transactions

What is it?

State law requires that state employees disclose certain business transactions with the State of Georgia or any of its agencies, including the University, on an annual basis by January 31.  These transactions can include transactions between a business entity in which the employee or a member of their family owns at least 25% of the interest.  An employee who does not engage in any of the qualifying transactions does not need to file a report.  This disclosure is not driven so much by the individual’s role in an outside business activity but rather by whether qualifying transactions were made with the State.  More information can be found at https://ethics.ga.gov/board-authorities-and-commissions/ and on the Internal Risk, Audit, and Compliance website.

Why must I disclose?

The disclosures are required by state law.  O.C.G.A. 45-10-20 – 29 requires the disclosure by state employees of certain business transactions. 

What must be disclosed?

The statute requires that qualifying transactions in excess of $250.00 be reported.  Transactions under $250.00 do not need to be reported unless the transactions exceed $9000.00 in the aggregate.  There are several exemptions to disclosures.  For more information, you can reach out to Internal Risk, Audit, and Compliance at 912-478-5521 or the Office of Legal Affairs at 912-478-7481.

How do I disclose?

Disclosures are made electronically directly to the State of Georgia.  Detailed instructions for submitting this report are available from the Georgia Government Transparency website.  Please file your registration and report online.