Author: Fearney, Kimberly

UConn Web Policy

Title: UConn Web Policy
Policy Owner: Information Technology Services
Applies to: Faculty, Staff, Students
Campus Applicability: All departments at all campuses except UConn Health
Effective Date: February 24, 2009
For More Information, Contact ITS
Contact Information: (860) 486-4357
Official Website: https://its.uconn.edu/

 

Background and Reason for the Policy: The University of Connecticut’s World Wide Web presence is increasingly an important method for communicating with students, faculty, staff, alumni, parents and friends of the University. As the role of the Web expands, it is essential that there be clear guidelines regarding the creation and maintenance of University websites.

Creativity and diversity are important components of an academic community – however, through the establishment of an identity program in 1998, the University of Connecticut has made a significant commitment to its existence and image as “one university.”

Purpose of Policy: The purpose of this policy is to provide clarification of standards, consistent with Federal, State and University laws and policies, for displaying information on any official University website that is accessed or pointed to through the main University website.

Expected Institutional Outcome:Adherence to this policy will result in a University web presence that provides important University information for effectively communicating with varied audiences while providing a consistent University image and remaining in compliance with Federal, State and University laws and policies.

Applicability of Policy: This policy applies to all developers of University of Connecticut web pages

Definitions:

University website: The University website comprises the main University website (www.uconn.edu) and the publicly-accessible homepages and websites of departments, offices, and other units of the University.

Main University website: The main University website is located at www.uconn.edu and is managed by University Communications.

Official University websites: Official University of Connecticut websites are those that have been sponsored by the University of Connecticut, whether they are stored on the University’s central server or on a University distributed server.

Official University webpages: Official University of Connecticut webpages are those that have been created by the University, its campuses, colleges, schools, departments or other administrative units, for University business. Official University webpages clearly convey a relationship to the entire University and support and advance the University’s mission.

Unofficial websites: Websites that are hosted but not sponsored by the University of Connecticut. The University of Connecticut does not endorse, regulate or maintain the contents of these sites, nor does it accept responsibility for the information contained in these websites.

Unofficial webpages: Individual webpages created by faculty, staff, students or student organizations. The University of Connecticut does not endorse, regulate or maintain the contents of these pages, nor does it accept responsibility for the information contained in these webpages.

Please see the links below for policies that complement the University of Connecticut Website Policy:

Electronic Privacy and Disclaimer Notice

Web Site Accessibility

Policy Statement: The rights of academic freedom and freedom of expression apply to the University website. However, all Official University websites must adhere to all applicable Federal and State statutes and University policies, including the University’s Acceptable Use policy.

Per a March, 2007 directive by the President’s Office, all Official University webpages must adhere to University Web Standards developed in collaboration by University Communications and ITS.  These standards, as well as technical resources, are defined at the WebTools website.  In addition, all Official University webpages must clearly convey a relationship to the entire University and adhere to the University Logos and Graphic Standards.

The University Web Standards do not apply to password-protected University web applications.

Responsibilities:

The Chief Information Officer has overall responsibility for this policy.

University Communications is responsible for overseeing the content and design of the main University website and for maintaining and publishing the University Web Standards.

The University’s webmanager in the Office of University Communications is responsible for approving all links to the main University website based upon the linked site’s adherence to this policy.

A department head or equivalent administrator will be considered the “owner” of a unit’s website and will be responsible for the overall function of the information it contains and for the adherence of its website to this policy.

A technical contact (webmaster, webmanager or site administrator) must be appointed by the website owner to maintain the website and its data. This technical contact will be the unit’s website administrator. The functions of the website administrator include:

  • Adhering to University website policies and regulations, along with any additional department policies and procedures;
  • Keeping the website consistently on-line and available to users;
  • Implementing and maintaining the website software and the hardware, if maintaining their own server, including providing security for and integrity of the data; and
  • Staying informed with respect to changes to website policies and University Web Standards.

Deans, directors and department heads may, at their discretion, permit individuals from their unit to display personal home pages through the department’s home page. However, if a personal website is found to be in violation of University or other appropriate policies, regulations or laws, the link from the department’s website may be removed until the issue is addressed.

Enforcement and Review:

The University reserves the right to deny publication or to remove from display any information that is considered inconsistent with published policies and practices.

Requests for exemption to this policy should be directed to University Communications, accompanied by written justification for the exemption request.

This policy and the University Web Standards will be reviewed on a bi-annual basis.

Restrictions of Publication Rights and Foreign Nationals in Sponsored Research Contracts

Title: Restrictions of Publication Rights and Foreign Nationals in Sponsored Research Contracts
Policy Owner: Vice President for Research and Graduate Faculty Council Executive Committee
Applies to: Faculty, Staff, Students, Others
Campus Applicability:
Effective Date:  April 6, 2004
For More Information, Contact Sponsored Program Services
Contact Information:  (860) 486-3619
Official Website: https://ovpr.uconn.edu/services/sps/proposals/

 

 

INTRODUCTION

This policy outlines the conditions under which UConn can accept restrictions on publication rights and foreign nationals in sponsored research contracts.  This policy is necessary because federal export control regulations (including International Traffic in Arms Regulations – ITAR) severely restricts all publication by PIs and carries severe sanctions.  Under these regulations federal agencies can withhold the right to publish, including a thesis.  Accordingly, the policy’s goal is to safeguard graduate students’ progress towards graduation while allowing them to gain valuable experience working on such sponsored research projects.

KEY ELEMENTS OF THE POLICY

A grant with restrictions on foreign nationals and publication rights can be accepted only if the following conditions are met:

1)      The Principal Investigator (P.I.) must show that graduate students will not be employed on the project for more than 6 months.  This determination will be made on a case-by-case basis and is not automatic.  Six months is the maximum appointment to be considered.  Furthermore, in the future similar work should be done by a technician or post-doc.

2)      The student must understand that the work cannot be part of his/her thesis because of the restrictions.  In addition, it is important that the student or post-doc understands that he/she cannot discuss the research with others in the lab and cannot allow anyone (besides the P.I.) access to the research data.   This information will be conveyed to each student and post-doc in a letter provided by the P.I.

3)      The P.I. must outline procedures to guarantee in writing that no other employee in the lab will have access to the data.  The PI must also guarantee that the work and resulting data will not be discussed in group meetings.

4)      The P.I., as well as each graduate student and post-doc, must sign the statements described in Sections 2 and 3 of this Policy.  OSP must get a signed copy of each statement before funds are released.

5)      The P.I. must be informed by OSP that the consequences of federal oversight on contracts with these restrictions can be severe, both for the individual and the institution.  The procedures outlined in this Policy are designed to protect him/her.

6)      The Associate Vice Provost may meet with the affected graduate student to ensure that he/she understands the Policy.

Responding to Requests for University Information, Policy on

Title: Responding to Requests for University Information, Policy on
Policy Owner: Information Technology Services
Applies to: Faculty, Staff
Campus Applicability:
Effective Date: October 22, 2007
For More Information, Contact Assistant VP for IT Security, Policy & Quality Assurance
Contact Information: (860) 486-4357
Official Website: https://its.uconn.edu/

Background and Reason for the Policy:

The University of Connecticut views University data, in all its forms and throughout its life cycle, as an asset of the University.  As an asset, University data must be protected to meet both Federal and State laws such as:

  • the Family Rights and Privacy Act (FERPA),
  • the Health Insurance Portability and Accountability Act (HIPAA),
  • the Electronic Communications Privacy Act (ECPA),
  • the Gramm-Leach-Bliley Act and
  • the Freedom of Information Action (FOIA),

as well as to comply with the policies of the institution.

However, many employees may not understand all of the confidentiality rules for the data to which they have access.  In addition, there has not been a clear protocol for dealing with requests for University data.

Purpose of Policy:

This policy is intended to direct employees of the University of Connecticut to whom requests for information may be made.

Expected Institutional Outcome: It is expected that this policy will provide the University community with a protocol for handling internal and external requests for University data.

Definitions:

  • Data Classification Policy:  See Data Classification Policy
  • Data Custodian: The entity/entities or office/offices that is/are delegated with the day-to-day operational-level responsibility of performing management functions for a defined portion of University data (i.e. specific administrative data sets) based on the definitions, procedures and guidelines developed by the Data Steward.
  • University Data:  Any recorded data or information relating to the University’s business prepared, owned, used, received, or retained by the University and its employees and agents, whether such data or information is handwritten, typed, tape-recorded, printed, photostatted, photographed or recorded by any other method.
  • External Requests: External requests are those made by individuals, agencies, groups or other entities outside of the University or by University members not acting in their official University capacity.
  • Internal Requests:  Internal requests are those made by a University office, a University employee, or a student.
  • Legitimate Business Purpose: A University Official has a Legitimate Business Purpose if the disclosure is relevant and necessary in the ordinary course of the requestor’s official duties and is related to the purpose for which the information was acquired.  Any University official who needs University Data in the course of performing instructional, supervisory, advisory, or administrative duties for the University has a Legitimate Business Purpose.
  • Official University Webpages: Official University of Connecticut webpages are those that have been created by the University, its campuses, colleges, schools, departments or other administrative unit, for University business.  Official University webpages clearly convey a relationship to the entire University and support and advance the University’s mission.
  • Publicly-Available:  Any information that is either published on one of the Official University webpages, the Undergraduate or Graduate Catalog, or other official University publication.
  • Non-publicly Available: Information that the employee gains by reason of employment with the University and that he/she knows or reasonably should know has not been made available to the general public.
  • University Official: A University Official is a University employee, administrator, officer, staff, professional, and any other individual who has been authorized by the University to act on behalf of the University.

Statement of Policy:

1. Internal Requests for Information:

  • Employees are permitted to disclose Publicly-Available University Data or to disclose Non-Publicly Available Data to a University Official with a Legitimate Business Purpose.  Employees may release information regarding individual student to that individual student.  All other requests should be referred as indicated below.
  • Requests for individual law student educational information or for lists of individual Law School student educational information should be referred to the Law School.
  • Requests for individual medical or dental student educational information or for lists of individual Medical School or Dental School student educational information should be referred to the University of Connecticut School of Medicine or School of Dentistry, respectively.
  • Requests for individual graduate student educational information by anyone other than the individual student, or for lists of individual graduate student educational information, should be referred to the Graduate School.
  • All other requests for student educational information by anyone other than the individual student, or for lists of individual student educational information, should be referred to the Registrar’s office.
  • Requests for individual employee personnel information by anyone other than the individual employee, or for lists of individual employee personnel information, should be referred to the Human Resources office.
  • Requests for summary University information should be referred to the Office of Institutional Research.
  • Requests for information concerning University purchases and procurement contracts should be referred to the Purchasing Department.
  • Requests for information on funded research should be referred to the Office of Sponsored Programs.
  • Requests for financial University data should be directed to the Chief Financial Officer.
  • Requests for information concerning University facilities should be directed to the Chief Operating Officer.
  • Requests for all other University Data should be directed to the appropriate Data Custodian.

2. External Requests for Information:

  • All external disclosures of University Data not defined as Publicly Available must comply with federal and state laws, as well as University policies.  University employees are only permitted to disclose University data to an external individual or entity that is Publicly Available except when permission has been given by those individuals whose information is being requested or under the exceptions listed below.
  • All requests for information from the news media should contact the Office of University Communications/University Relations, which will coordinate the response.
  • All requests for educational records concerning individuals other than oneself should be forwarded to the appropriate office:

–     University of Connecticut School of Medicine or School of Dentistry for records involving medical or dental students;

–    Law School for records involving law school students;

–    Registrar’s Office for records involving undergraduate or graduate students.

  • All requests for Student Employment Verifications and Student Job References should be directed to the Student Employment Office.
  • All requests for External Job References should be directed to Human Resources.
  • All court orders, subpoenas, warrants, or other legal instruments should be immediately forwarded to the Office of the Attorney General.
  • All other external requests for such information must be made in writing and referred to the University’s Privacy Officer.
  • A log of all external requests for information will be maintained by those offices that respond to such requests.

3. Exceptions:

  • Offices and employees who are responsible for regularly supplying the public with information pursuant to inquiries or requests need only refer the request to the University’s Privacy Office or the Attorney General’s office if the information is not usually communicated through that office or employee, or if the office or employee is unsure of the propriety of releasing the information.
  • Responses to questionnaires and surveys that require the provision of University aggregated data that has not been published should be directed to the Office of Institutional Research (OIR).  Each year, the OIR publishes statistical information which contain official University data and which is available from the OIR website.  Employees receiving such requests should use this published information as a primary source of information for completing questionnaires and surveys before sending them to the OIR for review.
  • If a request for information can be answered in its entirety from publicly-available information, the information may be provided by an employee or office.

Responsibilities:

The President, and/or their designee(s), has overall responsibility for implementation and enforcement of this policy.

Review of this policy by the President and/or their designee(s) will occur biennially.

Violations of this policy will result in appropriate disciplinary measures in accordance with University Laws and Bylaws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Conduct Code.

Records Management Policy

Title: Records Management Policy
Policy Owner: University Archivist, Records Management
Applies to: Faculty, Staff, Others
Campus Applicability: All
Effective Date: March 11, 2009
For More Information, Contact University Archivist, Records Management
Contact Information: (860) 486-4507
Official Website: https://rim.uconn.edu/

Background and Purpose of the Policy

The University of Connecticut is an agency of the State of Connecticut.  As a state agency, the University is, and therefore its employees are, required to conform to state regulations and statutes.

Under Section 11-8a of the Connecticut General Statutes the University has the obligation to handle, maintain, retain, dispose of and in cases destroy records in a certain manner, following specific processes and schedules.

The purpose of this policy is to provide guidance and reference for University employees regarding the retention, disposition, storage and destruction of official University records, in all formats.

Definitions

Record Connecticut public records are defined in General Statutes Section 1-200(5) as: “any recorded data or information relating to the conduct of the public’s business–prepared, owned, used, received, or retained by a public agency, whether such data or information be handwritten, typed, tape-recorded, printed, photostatted, photographed, or recorded by any other method.”  Recorded data and information that meet this definition are covered by this Records Management Policy.

Non-Record By definition, the term “non-records” means recorded data or information that does not meet the above definition of the term “record”.  The physical characteristics of non-record materials are the same as record materials. The differences between a non-record and a record are the reasons for keeping the information and how the information is used. Non-records are not covered by this Records Management policy and therefore do not need to be retained, stored, disposed of or destroyed in accordance with procedures create under this policy and state law.

The following are examples of “Non-Records”:

  • Extra copies kept only for convenience.
  • Informational copies of correspondence and other papers on which no documented administrative action is taken.
  • Duplicate copies of documents maintained in the same file.
  • Requests from the public for basic information such as manuals and forms that do not have any administrative retention requirements.
  • Transmittal letters that do not add information to that contained in the transmitted material.
  • Reproduced or published material received from other offices which requires no action and is not required for documentary purposes. The originating agency is required to maintain the record copy.
  • Catalogs, trade journals, and other publications or papers received which require no action and are not part of a case upon which foreseeable action will be taken.
  • Library or museum material collected for informational or exhibition purposes.
  • Stocks of publications, forms, or other printed documents which become obsolete or outdated due to revision. The originating agency should maintain a record copy.
  • Working papers, preliminary drafts, or other material summarized in final or other form and which have no value once action has been taken.

Record Series — A group of similar or related records that are normally used and filed as a unit and can be evaluated as a unit for determining the record retention period. All of the records that make up a record series must have the same retention periods. You cannot break up a record series into individual records and give each record a different retention period.

Records Retention Schedules — A comprehensive list of record series which indicates for each series the length of time it is to be maintained until it is reviewed for destruction or archival retention. It also indicates retention in active and inactive storage areas.

Policy Statement

All employees of the University of Connecticut are required to be aware of the fact that records management procedures exist, and to ensure that records are maintained, retained, stored, disposed of and, as appropriate, destroyed only in accordance with such procedures and the Records Retention Schedules.  The University’s Records Management Procedures are available at http://records.compliance.uconn.edu/.  Employees are urged to visit this website to keep up to date as changes to the procedures and/or the Records Retention Schedules can and do occur.  All updates to Records Management Procedures and Records Retention Schedules are posted to the website.  Employees may also contact the University Archivist at (860) 486-4507 for further information.

Re-Employed Retirees, Policy on

Title: Re-Employed Retirees, Policy on
Policy Owner: Office of Human Resources
Applies to: All State of Connecticut Re-Employed Retiree Employees
Campus Applicability: All Campuses, including UConn Health
Approval Date: July 11, 2023
Effective Date: July 11, 2023
For More Information, Contact Office of Human Resources
Contact Information: (860) 486-3034 (Storrs/Regional) / 860-679-2426 (UConn Health)
Official Website: https://hr.uconn.edu/
https://health.uconn.edu/human-resources/

BACKGROUND

The University re-employs retirees who have particular expertise necessary to meet a variety of academic, clinical, research, programmatic and/or administrative needs at a cost savings or benefit to the University and the state of Connecticut. In addition, as a research university and recipient of federal and other grants, the University has significant contractual and compliance obligations to granting agencies. The ability to retain particular expertise in the clinical, academic, and/or research setting, particularly when those retired employees generate revenue or are supported by external funding, is appreciably served by the use of re-employed retirees.

GENERAL POLICY

The University may re-employ retirees when operational, administrative, and/or financial benefits dictate or when needed to maintain continuing operations. Except as otherwise provided below, re-employed retirees may not be re-employed for more than three calendar years and shall not work more than 120 days/960 hours during any one calendar year.

The hourly compensation rate for individuals rehired into the same position from which the individual just retired shall generally not exceed 75% of the hourly rate paid to such employee in the last pay period immediately prior to his or her retirement for 120 days of work. The compensation rate for individuals rehired into different jobs from which they retired should be consistent with the assigned duties to be performed but shall generally not exceed 75% of the pre-retirement hourly rate.  Faculty and other employees that are non-time reporters prior to retirement, and therefore do not have a pre-retirement hourly rate, shall be restricted to post-retirement compensation not to exceed 75 percent of their pre-retirement annual salary.   Re-employed retirees are not eligible for annual mass salary adjustments.  Re-employed retirees may receive adjustments to salary if warranted by the duties and responsibilities of the position as long as all other terms of this policy are met.

Unclassified rehired retirees can be hired into any special payroll title; classified re-hired retirees must be hired into the appropriate Job Code as identified by the State of Connecticut to allow for appropriate tracking.

Appointments of re-employed retirees shall be reviewed by the President, Provost, Executive Vice President of Health Affairs (at UConn Health), or their designee and Human Resources to assess the continued operational needs and to ensure conformance with this Policy.  Proposals to re-employ retirees into senior administrative positions require prior review and approval by the President, Provost, Executive Vice President of Health Affairs, or their designee.

Some examples of appropriate uses for re-employed retirees include:

  • Maintain employees with unique, specialized knowledge and skills where qualified replacements cannot be immediately recruited or where it is financially beneficial for the University to maintain their expertise;
  • Provide qualified staff on a temporary or project basis when part or full-time positions are neither operationally sufficient nor financially beneficial;
  • Prevent the loss of potential revenues generated on grants or contracts;
  • Mitigate against a threat to patient or public safety;
  • Meet immediate and essential staffing needs required by accrediting agencies (e.g., the Joint Commission, DPH, or other regulatory bodies);
  • Secure the expertise of uniquely qualified researchers or staff in support of extramural funding or established grant projects;
  • Cover contractually or legally mandated leaves of absence (e.g., FMLA);
  • Provide clinical coverage to prevent the loss of clinical revenues or reduce use of agency staff through ongoing float positions;
  • Maintain continuity of operations through employment of individuals with particular expertise or experience at a cost savings;
  • Utilize employees with unique, specialized knowledge and skills for short-term projects or durational assignments.

EXCEPTIONS

Exceptions to the compensation and/or three calendar year maximum may be made with approval of the President, Provost, or Executive Vice President of Health Affairs at UConn Health, or their designee. Exceptions should be made when appropriately justified and reasonable in light of the goals expressed in the State of Connecticut’s Executive Order 27A related to the re-employment of retired state employees.  The maximum allotted time to work per calendar year for any rehired retiree is the equivalent of 120 days or 960 hours; exceptions may not be made to this provision of the Policy.

Some common exceptions include the following:

Instructional/Academic/Research Positions

Appointments of faculty and other staff who primarily perform research activities as re-employed retirees may be extended for the term of the extramural funding. Faculty who are hired in an academic capacity to mentor or advise students and provide other academic support to a School/College/Department.

Clinical Positions

Per diem, float, and direct patient care positions based on clinical need.

Adjunct Faculty

Employees who retire from state service and then serve as adjunct faculty. Teaching a maximum of 12 load credits per calendar year is equivalent to 120 days per calendar year.

Seasonal Employees

Employees who serve in seasonal roles, not to exceed three months in any calendar year.
The above are examples only and not intended to be exhaustive. Each exception request should be reviewed to determine if it is in the best interests of the University and consistent with the intent of this Policy.

APPROVAL HISTORY

April 21, 2009 Approved by the Board of Trustees:
August 7, 2013 Revised and Approved by the Board of Trustees
July 11, 2023 Revised and Approved by the President and Senior Policy Council

Providing Information in Alternative Formats, Policy on

Title: Providing Information in Alternative Formats, Policy on
Policy Owner: Office of Institutional Equity
Applies to: Workforce Members, Students, Others
Campus Applicability: All Campuses, including UConn Health
Approval Date: August 20, 2024
Effective Date: August 21, 2024
For More Information, Contact Office of Institutional Equity
Contact Information: equity@uconn.edu
(860) 486-2943
Official Website: https://accessibility.uconn.edu/

PURPOSE

The University of Connecticut, including the School of Law, Regional Campuses, and UConn Health, is committed to ensuring effective communication to all individuals, including those with disabilities in compliance with the Americans with Disability Act and its Amendments (2008) as well as Section 504 of the Rehabilitation Act of 1973.  This policy looks to address the needs of persons with disabilities who require access to University materials in alternative formats.

DEFINITIONS

University Workforce Members: Employees, volunteers, trainees, and other persons whose conduct, in the performance of work for the University, is under the direct control of the University, whether or not they are paid by the University.

POLICY STATEMENT

The University engages in an interactive process with each person making a request for accommodations and reviews requests on an individualized, case-by-case basis.  In keeping with these standards, the University requires that:

  • Printed materials be made available in alternative formats upon request. Printed materials include, but are not limited to, departmental/program brochures, announcements of events and activities, newsletters, exams, applications, forms, and any other printed information made available to the public.
  • Films and videos promoting departmental and program information, or related items acquired by a department or program, be closed captioned;
  • Departments and programs that sponsor public speakers, conferences, information sessions, or public performances provide qualified interpreters for people with hearing disabilities and printed materials in alternate formats upon request;
  • Departments and programs establish procedures to respond to requests in a timely fashion and promptly notify the Center for Students with Disabilities (CSD) of student accommodation requests, and the Office of Institutional Equity (OIE) of employee accommodation requests.
  • Departments and/or organizations should plan accordingly to use normal budgetary channels to provide assistive technology or alternative formats

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.

PROCEDURES/FORMS

Persons requesting materials in alternative formats, captioning for video and/or live speakers, or other assistive technology should submit their request to the appropriate entity at the University for review.  The designees are as follows:

Student Requests:

Students, including students enrolled at the School of Law, School of Social Work, School of Medicine, and School of Dental Medicine, should contact the Center for Students with Disabilities at their earliest convenience.  Students will be assigned a Disability Services Professional to assist them with their educational access throughout their time at the University.  More information on CSD and its process can be found here: csd.uconn.edu.

Contact:

Center for Students with Disabilities
Wilbur Cross Building, Room 204
233 Glenbrook Rd. Unit 4174
Storrs, CT 06269-4174
Phone: 860-486-2020
Video Phone: 860-553-3243
Email: csd@uconn.edu

Workforce Requests:

Any employee, including those at UConn Health, should submit their requests to Human Resources at their earliest convenience. Employees will have the opportunity to work with the ADA Case Manager to discuss their needs and make requests through the interactive process.  More information on HR’s process can be found:

UConn ADA Compliance & Accommodations
UConn Health ADA Compliance & Accommodations

Contact UConn:

ADA Accommodations Case Manager

Allyn Larabee Brown Building

9 Walters Ave Depot Campus – Unit 5075

Storrs, CT 06269-5075

Phone: (860) 486-2598

Email: tiffanie.roback@uconn.edu

Contact UConn Health:

ADA Case Manager

16 Munson Road, 5th Floor

Farmington, CT 06032

Phone: (860) 679-2426

Email:  moreland@uchc.edu

 

The University’s Interim ADA Coordinator is:

Sarah Chipman
Interim Associate Vice President, Interim Equal Employment Opportunity Officer, Interim ADA Coordinator, Director of Equity Response and Education, Deputy Title IX Coordinator
Office of Institutional Equity
Storrs: Wood Hall, First Floor
UConn Health: Munson Road, Third Floor
sarah.chipman@uconn.edu
(860) 486-2943

All other requests should be made directly to the facilitator or organizer of the program in question.  This information can often be found on the event’s website or other promotional materials.  Event organizers should make every effort to accommodate requests as needed and should work to promote accessible design within their program.  This can include producing large print programs, hiring captioning services or utilizing high contrast materials.

POLICY HISTORY

Revisions:
07/28/2015
08/20/2024 (Approved by the Senior Policy Council and President)

                               

Payment of Meals Policy

Title: Payment of Meals Policy
Policy Owner: Accounts Payable, Purchasing, Environmental Health and Safety
Applies to: Faculty, Staff
Campus Applicability:  Storrs and Regional Campuses
Effective Date:  July 15, 2015
For More Information, Contact Accounts Payable
Contact Information: (860) 486-4137
Official Website: www.accountspayable.uconn.edu

From time to time, it is necessary to the interests of the University to host or provide meals to guests such as job candidates, visiting scholars or donors. Likewise, a meal may be an essential or important part of an event, such   as a conference or workshop, which is conducted by the University. In cases where the University provides a meal (or reimburses the expense of the meal, as the case may be) to individual(s) who are not travelling on behalf of the University (herein defined broadly as “business meals”), the University will pay or reimburse the business meal under the requirements and procedures under this section.

As a public agency, the University has an obligation to students, taxpayers and benefactors to use all of its funds as prudently as possible. Therefore, all employees and individuals with authority to request, control or approve University funds, including but not limited to travelers, shall use their best judgment in applying those funds towards business meals only when justified with a business purpose and a clearly identifiable benefit to the University. The act of requesting, using or approving a business meal constitutes an individual’s official determination that, to the best of such individual’s knowledge, the expense was actually incurred, is justified by a business purpose, and serves the best interests of the University.

The University’s policy of paying or reimbursing for business meals is subject to the following general rules:

  1. University employees are generally responsible for paying for their own meals when they are not traveling.
  2. University funds may not be used for meals at social functions, such as parties or summer outings, attended entirely or primarily by University employees and/or their personal guests.
  3. University funds may not be used to purchase alcoholic beverages.
  4. In most cases, business meals may not be charged to sponsored awards (the responsible OVPR, SPS Grant Manager may provide more information or grant exceptions where appropriate).

Meals between faculty/staff and students, while allowable when there is a business justification, should be infrequent.  In addition, units may purchase group business meals when a group meal is essential to the effectiveness and efficiency of the meeting. This is especially the case when multiple units are called together for a substantial meeting, or when stopping the meeting to allow employees to leave for a normal meal would be disruptive and inconvenient for the University.

For the avoidance of doubt, this policy shall extend fully to business meals that are paid for by interdepartmental transactions, such as meals purchased through Dining Services (including Chuck and Augie’s). Business Meals require the documented approval of the Department Head, Director or Dean. The approval request should include the purpose of the meeting or event; a formal written agenda including session times; a list of attendees with their associated departments/entities; and the expected cost of the meal per person.  Set-up and delivery costs associated with the group meal shall not be included in the meal limit calculation.

For all business meals, including group meals, organizers should limit attendance to essential guests only. Without proper justification on the Business Meal Detail Form, the University will not reimburse expenses for spouses or partners or non-essential guests. Under no circumstances may the cost of the meal for each guest (including taxes and tip) exceed three times the appropriate GSA Per Diem meal amount for the location.

For the purposes of this policy, business meals shall not include refreshments, such as snacks or nonalcoholic beverages, which are made available to guests outside of the context of a meal. Such refreshments may be provided in appropriate business contexts, provided that the cost of providing refreshments, when combined with any meals served, is less than the applicable GSA meal rate (inclusive of incidental costs, such as set up, delivery, and service charges). For example, refreshments provided before a morning meeting at the Storrs campus cannot exceed the allowed breakfast per diem expense (currently $7 for FY15). Refreshment transactions must also be justified by a business purpose and require the attendee list, total costs, and per person breakdown before the costs may be paid or reimbursed.

Note that the provisions in this section shall not be construed as to supersede the provisions of any collective bargaining agreement.

Procedure

Departments with ability to control or request Foundation funds are encouraged to consider use of these funds as the primary reimbursement method to cover the expense of business meals.

If Foundation funds are not used, employees may request reimbursement for business meals by attaching the Business Meal Detail Form available at http://travel.uconn.edu/ with the original itemized receipt and proof of payment to the Reimbursement Request. Note that the form requires written approval for the meal from the Department Head, Director, or Dean. The Business Meal Detail Form must also include the date, location, business purpose, names of attendees and their affiliation to the University and the actual cost of the meal per person.

For authorized business meals at the Nathan Hale Inn and Conference Center, a Meal Charge Ticket allows departments to charge the meal to a KFS account.

Finally, for reference, the GSA Per Diem tables are available at: http://www.gsa.gov/portal/content/104877.

Units that want to contract for catering services for a group meal that will cost more than $2,000 should refer to UConn’s Procurement Services for guidance.

Refer to the Travel and Entertainment Policy – section 5e and complete the Business Meal Form.

Contracting and Paying for Catering Services For Events Costing Less than $2,000

University departments are authorized to contract for catering services without first obtaining a purchase order number, provided the total expenditure is less than $2,000. Departments making catering arrangements under this authority are encouraged to obtain a written and signed quotation from the selected vendor. If there is any question about whether the catering services might exceed $2,000, the department should obtain a purchase order number or PCard (PCard cannot be used for dine in options at off campus facilities) before the services are provided.

There are three alternatives for payments for the catering service:

  1. The vendor will invoice the University for the service. When the invoice is received by the department, a Disbursement Voucher should be prepared made payable to the vendor. The  Disbursement Voucher must contain:
    1. The purpose of the meeting
    2. Date of service
    3. Names of persons who attended and their relationship to the University
    4. The itemized invoice from the vendor attached to the Disbursement Voucher
  2. The preferred method of providing the required information is the Business Meal Detail Form. The host will pay the bill and obtain a receipt. A Disbursement Voucher made payable to the host should be prepared. The  Disbursement Voucher must contain:
    1. The purpose of the meeting
    2. Date of service
    3. Names of persons who attended and their relationship to the University
    4. The itemized invoice from the vendor attached to the Disbursement Voucher

The preferred method of providing the required information is the Business Meal Detail Form.

  1. The University PCard can be used for “take-out services” for student activities & official business meetings only for events less then $4,999.99

When reallocating in KFS attach the following:

    1. The purpose of the meeting/formal agenda
    2. Business Meal Pre-Approval Form signed by Department head
    3. Names of persons who attended and their relationship to the University
    4. The itemized receipt from the vendor

The PCard cannot be used to pay invoices for past events.

For Events Costing at Least $2,000 but Under $10,000

Catering services that cost at least $2,000 but fall below the bid threshold of $10,000 must be submitted to Procurement Services on a purchase requisition in advance of the required services. The requisition is required to contain the following before a purchase order will be issued;

    1. The purpose of the meeting/formal agenda
    2. Business Meal Pre-Approval Form signed by Department head
    3. Names of persons who attended and their relationship to the University
    4. A quotation from the vendor

The vendor will send the invoice with the Purchase Order # on the invoice to the Accounts Payable Office for payment.

The University PCard can be used for “take-out services” for student activities & official business meetings only for events less than $4,999.99.

For Events Costing $10,000 to $49,999.99

State procurement statutes require the University to competitively bid catering services when the cost is $10,000 or more.

If the department elects to obtain bids on their own, three (3) important points must be followed:

  1. The upfront research/legwork done by the department should eliminate vendors with an undesirable location. A minimum of three (3) written quotes should be solicited from three (3) vendors or three (3) facilities where you would be willing to hold your event.
  2. Your department’s requirements must be issued in writing to the vendors or facilities you are soliciting. It is essential that all vendors are provided the same information/requirements to bid and it is verifiable. Include a response date so you can negate any offers received after that date.
  3. Submit a purchase requisition along with all your supporting documentation as in the under $10,000 procedure. If no other information is needed by Procurement, a purchase order will be issued to the successful vendor.

Selecting the option most appropriate to accomplishing your objective will expedite the ordering process and reduce the amount of time spent filling out and filing forms.

If requested by department Procurement Services provides competitive bidding for catering as a service to those departments who wish to use it. To take advantage of this service, contact Procurement Services. The bids will be reviewed with the department prior to the award. A purchase order will be issued to the successful bidder.

For Events Costing over $50,000

For catering services and conferences that exceed a cumulative annual cost of $50,000 requires a public competitive bid process. The bid process must be handled in their entirety by the Procurement Services. Contact Procurement Services to discuss the competitive bid process. A purchase order will be issued to the successful bidder

The vendor will send the invoice with the Purchase Order # to the Accounts Payable Office for payment.

Public Health Code Requirements for Temporary Food Service Events & Catering

The Department of Environmental Health & Safety (EH&S) offers information and support to ensure that all food service establishments, including Temporary Food Service Events (TFSE), are held to the same consistent standard, and are operated in a safe and sanitary condition, helping to reduce the risk of a foodborne illness outbreak and ensure a safe food supply on campus.

All food served to the public (regardless if there is a fee or not) must be approved by EH&S.  Each organization serving food to the public must complete and submit a TFSE application to our office at least ten (10) business days prior to the event.  Good communication is essential for a smooth application process, enabling us to issue a timely approval and help ensure a safe and successful event.  TFSE applications submitted with less than ten (10) business days notice may not be approved and are subject to a late fee.  Upon approval, a permit will be issued which must be placed in an area visible to the public.

Please note that fully utilizing University Dining Services Catering exempts all organizations from having to submit a TFSE application; however, if they are only used for part of the event (for example, just purchasing food from University Catering), EH&S must receive a TFSE application.  All off-campus caterers must have a valid food license or permit from their local health department and a copy must accompany the TFSE application, if it is not already on file in our office.

The TFSE application can be submitted on-line at: http://ehsapps.uconn.edu/food/request.php

Safe food handling educational information and application fee information is available at: https://ehs.uconn.edu/food-safety-and-public-health/ or from the EH&S office located at 3102 Horsebarn Hill Road, Unit 4097, Storrs, Connecticut 06269-4097.  EH&S office hours are Monday-Friday from 8:00 AM to 5:00 PM.

The TFSE policy is intended to apply to “public” events, including:

  • Events (regardless of whether a fee is charged or not) that are widely advertised and where most anyone can attend, e.g., community picnics, large fundraisers
  • Open houses
  • Any public function that is, essentially, an open event, whereby the public has an expectation that the food is safe and complies with established public health codes.

The TFSE policy does not apply to “private” events, including:

  • Internal departmental functions, e.g., pot luck lunches/dinners, holiday gatherings, birthday parties, staff meetings
  • Student organization meetings, e.g., pizzas and refreshments ordered during discussions of club business by club members only
  • Typically small, private, gatherings by invitation only, e.g., a dean’s dinner party for potential donors

Please Note: Prior to the event, each applicant must attend a 30-minute Food Safety training session annually at the Environmental Health & Safety (EH&S) Office or at the Student Union Reservations Office, Room 315 (860) 486-3422. For more information on food safety or the TFSE application process, please contact the EH&S office at (860) 486-3613.

Insurance Requirements for Catering Contracts

All caterers serving at official University events are required to present evidence that they have both liability insurance and workers’ compensation insurance. A Certificate of Insurance is required from the [Vendor/Contractor]. Such certificate shall be issued by an insurance company with a general policyholder’s rating of not less than A- and a financial rating of not less than Class VIII as rated in the most current available A.M. Best Insurance Reports, and licensed to do business in the State of Connecticut.  The Certificate of Insurance shall name the University of Connecticut, State of Connecticut, its boards, commissions, agents and employees as an Additional Insured, and must be submitted to the Department owning the event/service prior to the catered event. Minimum acceptable coverage will include the following:

General Liability, including Contractual Liability, Products Liability, Broad Form Property Damage: $1,000,000 per occurrence/$2,000,000 aggregate

Automobile Liability: Any Auto $1,000,000 combined single limit

Excess Liability: Umbrella $1,000,000

Since the Procurement Services may not write purchase orders for catering services valued at less than $2,000, it will be the ordering department’s responsibility to ensure that the necessary documents are submitted and meet the above criteria. Any questions regarding insurance requirements for catering services should be directed to the Procurement Services at extension 6-4992.

Some small, specialty caterers may be unable to meet the one million dollar requirement. In such cases a waiver may be granted on a case-by-case basis, provided the total contract cost is less than $2,000. In such instances, the department wishing to utilize the catering services should submit to Procurement Services a letter explaining the unique capabilities of the selected firm, and a copy of the insurance certificate describing the amount of coverage available. Requests to hire uninsured caterers will not be approved. Any actions of uninsured caterers, which result in personal injury and/or property damage, i.e., food poisoning, scalding, spillage, or vehicular mishaps could potentially create a liability for the University.  It is the intent of this insurance requirement to mitigate the University’s liability exposure.

Exemption of Connecticut Sales Tax

Departments may be asked by the vendor to provide a Cert 112 or Cert 123 prior to the event in order to provide an exempt status for Connecticut Sales Tax. A Cert 112 provides exemption for a single event whereas a Cert 123 provides a blanket exemption for a year. If this is not filed prior to the event, the department is obligated to pay the Connecticut sales tax. Contact Procurement Services to inquire about particular vendors.

 

Non-Retaliation Policy

Title: Non-Retaliation Policy
Policy Owner: Office of the President
Applies to: Faculty, Staff, Students, Contractors and Affiliated Persons
Campus Applicability: All Campuses, including UConn Health
Effective Date: October 22, 2012
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530
Official Website: http://president.uconn.edu/

PURPOSE

To define how the University provides for the protection of any person or group within its community from retaliation who, in good faith, participates in investigations or reports alleged violations of policies, laws, rules or regulations applicable to the University of Connecticut.

POLICY STATEMENT

The University encourages individuals to bring forward information and/or complaints about violations of state or federal law, University policy, rules, or regulations.  Retaliation against any individual who, in good faith, reports and/or participates in the investigation of alleged violations, or who assists others in making such a report, is strictly forbidden.  This policy does not protect an individual who knowingly files a report or provides information as part of an investigation that is false or is filed in bad faith. The University will take appropriate action, up to and including dismissal, against any employee, student, or affiliated person who violates this policy.

DEFINITIONS

Retaliation: Any adverse action taken, or threatened against an individual because they have, in good faith, reported an allegation concerning the violation of state or federal law, University policy, rule, or regulation, or because they have participated in any manner with an investigation of such an allegation, or in an effort to deter an individual from doing so.

Examples of actions that may constitute retaliation include, but are not limited to:

  • unsubstantiated adverse performance evaluations or disciplinary action;
  • adverse decisions relating to the terms or conditions of employment or education;
  • interference with or denial of promotion or advancement opportunities (whether employment-related or academic);
  • reduction in a student’s grade;
  • interference with or denial of participation in University programs or activities;
  • unfounded negative job references or interfering with one’s job search;
  • denial or removal of co-authorship on a publication;
  • repeated intimidation or humiliation, derogatory or insulting remarks, or social isolation which may occur indirectly or directly from co-workers and/or a supervisor;
  • physical threats and/or destruction of personal or state property

Any action taken or threatened that would dissuade a reasonable person from engaging in activities protected by this policy may also be considered retaliatory.

Good Faith Report: A report made with an honest and reasonable belief that a university-related violation of law or policy may have occurred.

Bad Faith Report: A report made that is knowingly false and/or made with malicious intent.

Protected Activities: Good faith reporting, whether internally or externally, or inquiring about suspected wrongful or unlawful activity; assisting others in making such a report; and/or participating in an investigation or proceeding related to suspected wrongful or unlawful activity.

 

REPORTING PROCESS

If an individual believes that they have been subjected to retaliation, they should either contact the office to which the initial complaint was filed or any of the following University offices:

Storrs & Regional Campuses UConn Health
The Office of University Compliance
28 Professional Park, Unit 5084
Storrs, CT  06269-5084
Telephone: (860) 486-2530
Reportline: 1-888-685-2637Website: https://compliance.uconn.edu
The Office of University Compliance
Administrative Services Building
263 Farmington Avenue
Farmington, CT 06030-5329
Telephone: (860) 679-1969
Reportline: 1-888-685-2637Website: https://compliance.uconn.edu
The Office of Institutional Equity (OIE)
241 Glenbrook Road
Wood Hall, Unit 4175
Storrs, CT  06269-4175
Telephone: (860) 486-2943
Email: equity@uconn.edu
OIE’s Discrimination Complaint Procedures:
https://equity.uconn.edu/policiesprocedures/
The Office of Institutional Equity (OIE)
Munson Building
263 Farmington Avenue
Farmington, CT 06030-5130
Telephone: (860) 679-3563
Fax: (860) 679-3805
Email: equity@uconn.edu
OIE’s Discrimination Complaint Procedures: https://equity.uconn.edu/policiesprocedures/
Office of Faculty & Staff Labor Relations
9 Walters Avenue, Unit 5075
Storrs, CT  06269-5075
Telephone: (860) 486-5684
Website: https://lr.uconn.edu/ 
Employee/Labor Relations
Munson Building
263 Farmington Avenue
Farmington, CT 06030 – 4035
Telephone: 860-679-8067
Website: https://health.uconn.edu/human-resources/services/employee-labor-relations/
University of Connecticut Police Department
126 North Eagleville Road, Unit 3070
Storrs, CT  06269-3070
Telephone: (860) 486-4800
Website: https://publicsafety.uconn.edu/police/
University of Connecticut Police Department
263 Farmington Avenue
Farmington, CT 06030 – 3925
Telephone:  860-486-4800
Website: https://publicsafety.uconn.edu/police

Any individual who is covered by a collective bargaining contract are also encouraged to contact their union:

Union Contact Information
The American Association of University Professors (AAUP), University of Connecticut Chapter Telephone: (860) 487-0450

Website: http://www.uconnaaup.org/contact/

The University of Connecticut Professional Employees Association (UCPEA) Telephone: (860) 487-0850

Website: http://ucpea.ct.aft.org/

Maintenance and Service Unit,
Connecticut Employees Union Independent (CEUI)
Telephone: (860) 344-0311

Website: http://ceui.org/

Administrative Clerical Unit – American Federation of State, County and Municipal Employees (AFSCME) Telephone: (860) 224-4000

Website: https://www.afscme.org/

Connecticut Police and Fire Union Telephone: (860) 953-2626

Website: https://cpfu.org/

Social and Human Services Unit – American Federation of State, County and Municipal Employees (AFSCME) Telephone: (860) 224-4000

Website: https://www.afscme.org/

Administrative and Residual Employees Union (A&R) Telephone: (860) 953-1316
Website: http://andr.ct.aft.org/
New England Health Care Employees Union – District 1199 Telephone: (860) 549-1199

Website: http://www.seiu1199ne.org/

University Health Professionals (UHP) Telephone: (860) 676-8444

Website: http://uhp3837.ct.aft.org/

Nothing in this policy shall be deemed to diminish the rights, privileges or remedies of a University (State) employee under other federal or state law or under any collective bargaining agreement or employment contract.

 

ADDITIONAL RESOURCES

In addition to the resources above, the following offices may be helpful to University employees and students who believe they are experiencing retaliation.

Employee Assistant Program

Website: https://hr.uconn.edu/employee-assistance-program/

University Ombuds

Website: https://ombuds.uconn.edu/

Office of the Dean of Students

Website: https://dos.uconn.edu/

UConn Cultural Centers

Website: https://office.diversity.uconn.edu/cultural-centers/

Office for Diversity and Inclusion:

Website: https://diversity.uconn.edu/

 

POLICY HISTORY

Policy created:  09/22/2009

Revisions:

10/22/2012 (Non-substantive revisions)

05/03/2021 (Approved by President’s Cabinet)

Human Subjects Research

Title: Human Subjects Research
Policy Owner: Office of the Vice President for Research
Applies to: Employees, Faculty, Students, Others
Campus Applicability: All Campuses
Effective Date: May 25, 2018
For More Information, Contact Office of the Vice President for Research
Contact Information: (860) 486-3001
Official Website: http://research.uconn.edu/

REASON FOR POLICY

The University of Connecticut is committed to ensuring the safety, rights and welfare of all participants involved in human subjects research conducted at or by the University of Connecticut on all its campuses, including UConn Health (the “University”). This policy establishes that whenever the University engages in human research it will be guided by the ethical principles of the Belmont Report and will comply with applicable legal requirements. It is the responsibility of all components of the human research protection program to work collaboratively to ensure research with human subjects is conducted in accordance with such ethical principles and legal requirements.

APPLIES TO

All University faculty, employees, students, postdoctoral fellows, residents and other trainees, and agents who supervise or conduct human subject research.  Such research includes, but is not limited to, obtaining data through intervention or interaction with individuals, using identifiable private information or identifiable biospecimens from living individuals and using human tissue to evaluate the safety or effectiveness of an investigational device.

DEFINITIONS

Human Research Protection Program (“HRPP”):  The University’s comprehensive system designed to ensure that the University meets ethical principles and legal requirements for the protection of the safety, rights and welfare of human participants in research.  The HRPP encompasses all University-associated individuals and units responsible for the conduct and oversight of research involving human participants.

Human Subject or Human Participant:

  • A living individual about whom an investigator (whether professional or student) conducting research obtains data through intervention or interaction with the individual, or identifiable private information. [45 CFR 102(f)]
  • An individual who is or becomes a participant in research, either as a recipient of the test article or as a control. Such subject may be either a healthy individual or a patient. For research that evaluates the safety or effectiveness of a device, the definition also includes a human on whose specimen an investigational device is used. Such subject may be in normal health or may have a medical condition or disease. [21 CFR 56.102(e); 21 CFR 812.3(p)]
  • Any other individual meeting the legal requirements of a human subject or human participant in research.

Institutional Official (“IO”): The individual appointed by the President of the University who is legally authorized to act for and on behalf of the University in matters related to human subject research and the protection of human research participants. The IO oversees the HRPP and is responsible for ensuring that it functions effectively and that the University provides appropriate resources and support to comply with applicable legal requirements governing human subject research.

Institutional Review Board (“IRB”): A multidisciplinary group whose membership meets applicable legal requirements, which reviews, approves, and oversees all University research involving human subjects. An integral component of the HRPP, the IRB review ensures the protection of the safety, rights and welfare of human subjects and that applicable legal requirements are met.

Research:

  • A systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. [45 CFR 102(d)]
  • A clinical investigation, meaning any experiment that involves a test article and one or more human subjects, and that either must meet the requirements for prior submission to the Food and Drug Administration (“FDA”) under section 505(i) or 520(g) of the Federal Food, Drug, and Cosmetic Act, as amended (the “Act”), or need not meet the requirements for prior submission to the FDA under these sections of the Act, but the results of which are intended to be later submitted to, or held for inspection by, the FDA as part of an application for a research or marketing permit. [21 CFR 102(c)]
  • Any other activities meeting the legal requirements of research involving human subjects or human participants.

POLICY STATEMENT

The University will designate one or more IRBs for the review of research involving human participants.

The IO is delegated the authority to develop policies and procedures, and to implement a program to ensure the safety, rights and welfare of human participants in research that is legally compliant.

All human subjects research, regardless of sponsorship or funding, must be reviewed and approved by a University designated IRB before research begins unless specifically exempted from review by policy or procedure.

Designated IRBs are granted the authority to:

  • Approve, require modifications to secure approval, or disapprove research involving human subjects;
  • Suspend or terminate approval of research not being conducted in accordance with the IRB’s requirements or that has been associated with unexpected serious harm to human subjects;
  • Take actions determined necessary to ensure legal compliance and adherence to University policy, and to mitigate issues associated with unanticipated problems or risks to human participants and others;
  • Observe, or have a third party observe, the consent process or conduct of the research; and
  • Conduct continuing review of research annually or at intervals appropriate to the degree of risk.

University personnel may not approve research involving human participants if it has not been approved by a University designated IRB.  Research that has been approved by a designated IRB may be subject to further review and approval or disapproval.

Research Subject to the Common Rule. Human subject research that is conducted or supported by any federal department or agency that has adopted the Federal Policy for the Protection of Human Subjects, known as the Common Rule, will comply with the requirements set forth in the Health & Human Services Regulations at 45 CFR part 46 (including subparts A, B, C and D), unless the research is otherwise exempt from these requirements.  Relevant HRPP and IRB policies and other applicable legal requirements of the department or agency conducting or supporting the research may also apply.

Research Subject to FDA Regulation. Clinical investigations regulated by the FDA under section 505(i) or 520(g) of the Act (21 U. S.C. § 355(i)) will comply with the applicable FDA regulations. These regulations include, but are not limited to: Protection of Human Subjects (21 CFR part 50), Institutional Review Boards (21 CFR part 56), Investigational New Drug Application (21 CFR part 312), Applications for FDA Approval to Market a New Drug (21 CFR part 314) and Investigational Device Exemptions (21 CFR part 812).  Relevant HRPP and IRB policies may also apply.

Other Research. For all other research involving human participants, the University applies the policies of the HRPP, which are guided in their development and implementation by the Health & Human Services Regulations at 45 CFR part 46 (including four subparts) and the International Conference on Harmonization Good Clinical Practice Consolidated Guidelines.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, the University of Connecticut Student Code, and other applicable University Policies.

ADDITIONAL RESOURCES

45 CFR part 46 (including subparts A, B, C and D)

21 CFR part 50

21 CFR part 56

21 CFR part 312

21 CFR part 314

21 CFR part 812

ICH GCP (E6)

Belmont Report: Ethical Principles and Guidelines for the Protection of Human Subjects of Research (1979)

POLICY HISTORY

Revisions: 2/16/2011; 5/25/2018 (Approved by President’s Cabinet)

Guide to the State Code of Ethics

Title: Guide to the State Code of Ethics
Policy Owner: Office of University Compliance
Applies to: Faculty, Staff
Campus Applicability: All Campuses
Approval Date: October 25, 2023
Effective Date: October 25, 2023
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530 or universitycompliance@uconn.edu
Official Website: https://compliance.uconn.edu

PURPOSE

Pursuant to state law, the University is required to adopt in cooperation with the Office of State Ethics, an ethics statement as it relates to the mission of the University. The Code of Ethics for Public Officials (the Code) sets forth principles of ethical conduct that all state employees, including employees of the University, must observe. All employees of the University are expected to become familiar with the Code and comply with all its provisions. This statement is intended to be a general guide to assist you in determining what conduct is prohibited so that it may be avoided. It is not intended to supersede the Code. Please note that under state statute, compliance with the Code is the responsibility of the employee, not the University.

The Office of State Ethics has jurisdiction to interpret and enforce the Code. Violations may result in a formal complaint proceeding filed against the employee and sanctions of up to $10,000 per violation. The entire Code and regulations, as well as a summary of these rules, may be found at the Office of State Ethics website. For formal and informal interpretations of the Code of Ethics, employees should contact the Office of State Ethics.   In addition, the University must designate an Ethics Liaison as an information resource regarding compliance. An employee who has a question or is unsure about the provisions of this policy, or who would like assistance in contacting the Office of State Ethics, should contact the University’s Ethics Liaison.

The following general provisions of the Code are applicable to all employees of the University of Connecticut:

CONFLICT OF INTEREST

  •  GIFTS:  In general, employees are prohibited from accepting gifts, discounts or gratuities of any kind from prohibited donors: (1) doing business with or seeking to do business with the University; (2) directly regulated by the University; (3)  known to be a registered lobbyist or a lobbyist’s representative, or; (4) pre-qualified under Conn. Gen. Stat. §4a-100.  A list of registered lobbyists can be found on the web site of the Office of State Ethics.  Certain items are excluded from the definition of “gift,” including: items offered to the public at large (for example, trinkets provided at an open house), items valued at under $10, food and beverage up to $50 in a calendar year from each donor and training for a product purchased by the University provided such training is offered to all customers of that vendor.  “Gifts to the state” are also permitted as long as the gifts facilitate University actions or functions.  If an employee is offered a benefit from someone other than the prohibited donors listed above, and the benefit is offered because of the employee’s position at the University, the total value of benefits received from one source in a year must not exceed $100.  Additionally, supervisors may only accept gifts valued at no more than $100 from a subordinate; a subordinate may only accept gifts valued at no more than $100 from his/her supervisor.  This provision not only applies to direct supervisors and subordinates, but to any individual up or down the chain of command.  Questions regarding specific facts and circumstances surrounding various gift-giving scenarios should be directed to the University’s Ethics Liaison or the Office of State Ethics.
  • OUTSIDE EMPLOYMENT:  No employee may accept outside employment that will impair their independence of judgment with regard to their state duties or would encourage the disclosure of confidential information gained in state service. Additionally, although an employee may use their expertise, they may not use their state position to obtain outside employment. An employee is not allowed to use their business address, telephone number, title or status in any way to promote, advertise or solicit personal business.  Employees interested in pursuing outside employment may seek and receive written approval from their Supervisor and, if uncertain about the application of the Code, the Ethics Liaison or the Office of State Ethics. For faculty and professional staff, the University of Connecticut By-Laws specifically address consulting, private professional practice, teaching, and other outside employment situations. Faculty and members of the AAUP bargaining unit must adhere to the University’s Faculty Consulting policy as well as the policy on assigning textbooks which they have authored. Union members are referred to contract articles, if such exist, relating to outside employment in their respective collective bargaining agreements. If you are thinking about an opportunity for outside employment, you may also consult with the University’s Ethics Liaison for guidance.
  • FINANCIAL BENEFIT:  Employees may not use their official position or confidential information gained in their service for personal financial benefit, or the financial benefit of a family member or a business with which they, or a family member, are associated.  Employees are prohibited from using state time, personnel or materials, including telephones, computers, e-mail systems, fax machines, copy machines, state vehicles and any other supplies, for personal, non-state related purposes.  It is understood, however, that incidental use of state property for personal use is permissible so long as you reimburse the state for any identifiable charges.
  • CONTRACTS WITH THE STATE:  Employees, their immediate family members, and/or a business with which an employee or their family member is associated may not enter into a contract with the state valued at $100 or more, unless the contract has been awarded through an open and public process. The Code permits an exemption for contracts with a public institution of higher education to support a collaboration with such institution to develop and commercialize any invention or discovery.  The Office of State Ethics has ruled that immediate family members may not be hired as an independent contractor unless there has been an open and public process.
  • APPEARANCE FEES:  No employee may personally accept any fee or honorarium given in return for a speech or appearance made or article written in the employee’s official capacity.  Employees may, however, direct that the fee or honorarium be deposited in a University account to be used for future University-related business activities.
  • NECESSARY EXPENSES/GIFTS TO THE STATE: payment or reimbursement of expenses to participate in a particular event may be acceptable under certain circumstances and, if received from a non-governmental entity, may also require a disclosure filing with the Office of State Ethics. “Necessary expenses" are limited to: necessary travel expenses, lodging for the nights before, of and after the appearance, speech, or event; meals and any related conference or seminar registration fees. “Gifts to the state” may also be acceptable to attend an event that is relevant to your state duties and do not require “active participation”.

POLITICAL ACTIVITY

  1. Employees are not prohibited from seeking political office as long as it is not done on State time or with State equipment. However, any State employee who is elected to state political office may not be employed by two branches of state government simultaneously. Therefore, any employee who accepts an elective state office must resign or take a leave of absence from his/her position with the University. Consult the University By-Laws and inform your supervisor prior to participating in a political campaign.
  2. No employee of the University will engage in partisan political activities while on state time. Additionally, no employee will use state materials or equipment for the purpose of influencing a political election of any sort.

MISCELLANEOUS: POST-EMPLOYMENT (REVOLVING DOOR) AND VENDOR NOTIFICATION

The State Code of Ethics contains several provisions regarding post-state employment. Prior to leaving employment with the University, all employees should review the applicable rules and, if necessary, seek guidance from the Ethics Liaison or The Office of State Ethics.

  • You may never use confidential information for financial gain for yourself or any other person. This is a lifetime prohibition. “Confidential Information” is any information not generally available to the public.  The information may be in any form (written, photographic, recorded, computerized, etc.) including orally transmitted information, e.g., conversations, negotiations, etc.
  • You may not represent anyone concerning any particular matter in which you personally and substantially participated while in state service in which the state has a substantial interest.
  • You may not, for one year, represent anyone before your former agency for compensation
  • If you participated substantially in the negotiation or award of a state contract valued at $50,000 or more, you may not accept employment with a party to the contract for one year after leaving state service, if you resign within one year after the contract was signed.

No official or employee shall counsel, authorize or otherwise sanction action that violates any provision of the Code of Ethics.

The provisions of this document shall apply to all employees of the University of Connecticut. All current and future employees of the University shall be supplied with a copy of this document, and it shall be the responsibility of each employee to be familiar with these provisions and to comply with them. It is strongly suggested that employees avoid those situations which may give the appearance of being a conflict of interest. When in doubt or unsure about these provisions, an employee should contact either his or her supervisor, department head, or the University’s Ethics Liaison. Ultimately, The Office of State Ethics is the authority that determines what conduct constitutes an ethics violation under the law. Therefore, you are strongly encouraged to discuss any situation which may pose a conflict of interest or other ethics problem with the Office’s staff attorneys.

The University will notify vendors/contractors doing business with it of these provisions through its procurement officers. A summary of the State Code of Ethics as it applies to vendors will also be provided. Copies of this policy will be provided upon request.

Please note: Violations of the Code of Ethics may subject an employee to sanctions from agencies or systems external to the University. Whether this occurs or not, the University retains the right to independently review and respond administratively to violations. The conduct of the review and response will be in accordance with contractual and regulatory guidelines.

IMPORTANT ETHICS REFERENCE MATERIALS

It is strongly recommended that every employee read and review the following ethics materials:

The University’s Ethics Liaison is:

Kimberly Fearney, Associate Vice President and Chief Compliance Officer
Office of University Compliance
28 Professional Park Road (Unit 5084)
Storrs, CT 06268
Telephone Number: (860) 486-2530
Email: Kim.Fearney@uconn.edu

The contact information for the Office of State Ethics:

20 Trinity Street
Hartford, CT 06106
Office of State Ethics
Tel: (860) 263-2400
Fax: (860) 263-2402

POLICY HISTORY

Policy created: July 2006
Revisions: October 25, 2023; February 26, 2014; July 2009