Office of University Compliance

Use of Students in Outside Employment

Title: Use of Students in Outside Employment
Policy Owner: Office of University Compliance
Applies to: Faculty, Staff
Campus Applicability:
Effective Date: July 14, 2015
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530
Official Website: https://compliance.uconn.edu/

 

Background and Reasons for the Policy: The Code of Ethics for Public Officials preclude public employees from accepting other employment which will impair the employee’s independence of judgment or otherwise create a conflict of interest.

Purpose of Policy: To provide guidance on the employment of students by faculty and staff for work external to the University.

Expected Institutional Outcome: Compliance with the Code of Ethics.

Applicability of Policy: All employees.

Policy Statement: Pursuant to Connecticut General Statute Section 1-84(b) of the Code of Ethics for Public Officials, a state employee may not accept other employment which will impair his/her independence of judgment as to his/her official duties or employment.  Furthermore, in accordance with Connecticut General Statute Section 1-86 and the Regulations of Connecticut State Agencies Section 1-81-29, a state employee with a potential conflict of interest must inform his/her supervisor who shall assign the matter to another who is not subordinate to the individual with the conflict.

Potential conflicts may occur when a University employee hires a student in any non-University supported activity. Therefore, employees who choose to employ students in any non-University activity must obtain written approval from their Department Head/Dean/Director prior to employing the student. Faculty members who wish to hire a graduate student and who teach a course in which the student is enrolled, serve as a member of the student’s thesis or dissertation committee, or serve as the student’s advisor or the director of his or her thesis or dissertation research must also receive written approval from the Dean of the Graduate School.  The University requires that each student receive a written offer of employment with a specific scope of work or job description, the rate of compensation and the expected hours of work.  In addition, the student should receive a fair market value rate of pay.

Students have on-going recourse to the Provost who will consult with the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students) in order to address any grievances that may arise during the term of the employment.

Failure to comply constitutes a violation of the State ethics code and University policy and is subject to disciplinary procedures of both.

Responsibilities: All employees.

Use of Students in Outside Employment Letter Template

History

Revised: 07/13/2015; 12/16/2014; 06/23/2008

New Policy: 03/01/2004

Non-Retaliation Policy

Title: Non-Retaliation Policy
Policy Owner: Office of the President
Applies to: Faculty, Staff, Students, Others
Campus Applicability:  All Campuses
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, participate in investigations or report 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 or who participates in the investigation of alleged violations is strictly forbidden.  This policy does not protect an individual who files a report or provides information as part of an investigation that he or she knows is false, files a bad faith retaliation claim or participates in any illegal conduct.  The University will take appropriate action, up to and including dismissal, against any employee who violates this policy.

Definitions

Retaliation – Any inappropriate or unsubstantiated action taken or threatened against an employee because the individual has, in good faith, made an allegation concerning the violation of state or federal law, University policy, rule or regulation, or has participated in any manner with an investigation of such allegation.  Such actions adversely affect or threaten to affect the employment rights or other interests of an individual and can take either work or social form.

Examples of work-related retaliation may include, but are not limited to:

  • Unsubstantiated adverse performance evaluations or disciplinary action;
  • Unfounded negative job references;
  • Arbitrary denial of salary increases, promotions or other job benefits; and
  • Unfounded reduced or limited work assignments.

Examples of social retaliation in the workplace may include, but are not limited to:

  • discrimination or harassment from co-workers and/or supervisor;
  • bullying, which involves repeated intimidation or humiliation, derogatory or insulting remarks, or social isolation and which occurs indirectly (e.g., via e-mail) or directly;
  • hostile work environment, described as conduct that is so objectively offensive as to alter the conditions of employment; and
  • physical threats and/or destruction of personal or state property.

Actions also considered retaliatory include any action taken or threatened by an employee that would dissuade a reasonable employee from engaging in activities protected by this policy.

Good Faith Reporting – An individual is considered to have reported in good faith if s/he has brought forward the complaint or participated in providing information during an investigation, based upon a reasonable belief that the information provided is true.

Bad Faith Reporting – An individual shall be considered to have reported in bad faith if s/he has brought forward a complaint or participated in providing information during an investigation, knowing that such information is not true or made without a reasonable belief in the truth of the allegation based upon the facts.

Reporting Process

If an individual believes that he or she has been subjected to retaliation, s/he should either contact the office to which the initial complaint was filed or any of the following University offices:

Storrs and Regional Campuses

  • The Office of University Compliance
    28 Professional Park, Unit 5084
    Storrs, CT  06269-5084
    Telephone: (860) 486-2530
    Reportline: 1-888-685-2637
  • The Office of Institutional Equity (OIE)
    241 Glenbrook Road
    Wood Hall, Unit 4175
    Storrs, CT  06269-4175
    Telephone: (860) 486-2943
    Information on OIE’s Discrimination Complaint Procedures is available at:
    https://equity.uconn.edu/policiesprocedures/
  • Office of Faculty & Staff Labor Relations
    9 Walters Avenue, Unit 5075
    Storrs, CT  06269-5075
    Telephone: (860) 486-5684
    http://lr.uconn.edu/
  • Police Department
    126 North Eagleville Road, Unit 3070
    Storrs, CT  06269-3070
    Telephone: (860) 486-4800
    Emergency: 9-1-1

UConn Health

  • The Office of University Compliance
    University of Connecticut and UConn Health
    263 Farmington Avenue
    Farmington, CT 06030-5329
    Telephone: (860) 486-2530
    Reportline: 1-888-685-2637
  • The Office of Institutional Equity (OIE)
    16 Munson Road
    Farmington, CT 06030-5130
    (Physical)
    263 Farmington Avenue
    Farmington, CT 06030-5130
    (Mailing)
    Telephone: (860) 679-3563 Fax: (860) 679-3805
    Email: equity@uconn.edu
    Information on OIE’s Discrimination Complaint Procedures is available at https://equity.uconn.edu/policiesprocedures/.
  • Labor Relations at the Department of Human Resources
    263 Farmington Ave. Farmington, CT 06030 – 4035
    Telephone: 860-679-8067
  • Police Department
    263 Farmington Ave. Farmington, CT 06030 – 3925
    Telephone:  860-679-2511

Employees should expect that any of the above offices will direct her/him to the appropriate department for reporting the retaliation.

Resources Available For Assistance

There are resources on campus that can assist employees who are experiencing retaliation.  Individual advocacy through these resources in connection with specific incidents can include information and referrals, accompanying an employee through the hearing process, assistance with navigating other resources as requested and crisis-intervention services.

  • African American Cultural Center – (860) 486-3433
  • Asian American Cultural Center – (860) 486-0830
  • Employee Assistance Program – (860) 679-2877 or 800-852-4392
  • Puerto Rican/Latin American Cultural Center – (860) 486-1135
  • Rainbow Center – (860) 486-5821
  • Women’s Center – (860) 486-4738

Employees who are covered by a collective bargaining contract are also encouraged to contact their union for assistance:

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.

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
Effective Date: February 26, 2014
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530
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 (Connecticut General Statutes Section 1-79 et seq.) 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 are expected to comply with all of 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 of Ethics for Public Officials. 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 web site for the Office of State Ethics, www.ethics.state.ct.us.    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.

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.

The following general provisions of the Code of Ethics 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 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 of 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.  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 his or her independence of judgment with regard to his/her state duties or would encourage the disclosure of confidential information gained in state service. Additionally, although an employee may use his/her expertise, he/she may not use his/her state position to obtain outside employment. An employee is not allowed to use his/her 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 Department Head and, if uncertain about the application of the Code, the Office of State Ethics. For faculty and professional staff, the University of Connecticut Laws and By-Laws specifically address consulting, private professional practice, teaching, and other outside employment situations. 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 his/her 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 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.  You 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 to participate in a particular event may be acceptable under certain circumstances and, if received from a non-governmental entity, may also require the filing of a disclosure form 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.
  • The paramount issue to be considered is whether the activity in question is performed in an employee’s “official capacity.” As a general rule, if a university employee is asked to participate in an event, speak, appear, or write an article and the employee’s official position or authority was a significant factor in the decision to extend the invitation, then it will be deemed to be in his/her official capacity. If, however, a state employee has developed an expertise in a particular field and he/she is asked to participate in an event, speak, appear, or write an article as a result of his/her knowledge and expertise, then the employee is not prohibited from accepting a fee or honorarium. Note that these situations are very fact specific and employees are encouraged to contact the University’s Ethics Liaison for guidance.

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 Laws and 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: Confidential Information, Post-Employment, Vendor Notification

Many employees of the University have access to confidential information. Information may be deemed confidential pursuant to various state and federal statutes and/or University policy. Unauthorized release of confidential information is prohibited. If an employee is unsure whether certain information is deemed confidential, he/she should seek advice from his/her supervisor, prior to releasing such information.

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 Office of State Ethics.

  • Section 1-84a: 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.
  • Section 1-84b(a): 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.
  • Section 1-84b(b): You may not, for one year, represent anyone before your former agency for compensation
  • Section 1-84b(f): 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.

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 & Chief Compliance Officer
Office of University Compliance
28 Professional Park Road (Unit 5084)
Storrs, CT 06268

Telephone Number: (860) 486-2530
Fax Number: (860) 486-4527

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

Revisions: 2/26/2014; 07/2009

Original: 07/2006

Employment and Contracting for Service of Relatives, Policy on

Title: Employment and Contracting for Service of Relatives, Policy on
Policy Owner: Office of University Compliance and the Office of Faculty & Staff Labor Relations/Human Resources
Applies to: Faculty, Staff, Others
Campus Applicability: All Campuses
Effective Date: February 7, 2011
For More Information, Contact Office of University Compliance and the Office of Faculty and Staff Labor Relations (Storrs) or Human Resources (UConn Health)
Contact Information: UConn Health: (860) 679-4180 or (860) 679-2426
Storrs/Storrs Based Campuses: (860) 486-2530 or (860) 486-5684
Official Website:  https://compliance.uconn.edu/ethics-overview/ or http://lr.uconn.edu

 

Purpose:
The employment or contracting for service of relatives in the same department or area of an organization may cause conflicts and serve as the basis for complaints concerning disparate treatment and favoritism as well as violations of the state’s Ethics statute.

This policy is established to protect against such conflicts and complaints, and to provide for the ethical and legally consistent treatment of individuals with relatives seeking employment or who are employed by the University.

Policy:
No employee of the University of Connecticut may be the direct supervisor of or take any action which would affect the financial interests of one’s relative. This may include decisions regarding appointment, award of a contract, promotion, demotion, disciplinary action, discharge, assignment, transfer, approval of time-off, and approval of training or development opportunities, as well as conducting performance evaluations or participating in any other employment action, including serving on a search committee acting on a relative’s application, or otherwise acting on behalf of a relative except as noted under “Procedure” below. Further, no employee may use his/her position to influence an employment action of a non-relative if such action would benefit one’s relative.

For purposes of this policy, relative is defined as: spouse, child, step-child, child’s spouse, parent, brother, sister, brother-in-law, sister-in-law, dependent relative or a relative domiciled in the employee’s household.

Procedure:
The University recognizes the potential for conflict of interest, claims of disparate treatment and/ or discrimination in the employment of relatives in the same department, work unit or in a direct or indirect supervisory relationship. The University further recognizes that there are infrequent but compelling circumstances under which such employment relationships may be in the best interests of the institution. Thus, to protect both the involved employee and the institution in those situations, the following procedure must be followed.

  1. No employee may sign any document that would affect an employment action on behalf of a relative.
  2. An employee who is confronted with an employment decision or action involving a relative must inform the immediate supervisor in advance, in writing, of the situation. The employee will describe the relationship and the proposed action requiring a decision by using Section 1 of the Conflict of Interest (COI) Disclosure form available here.
  3. The COI is submitted through the supervisory chain to the dean/director and then to the appropriate senior manager.  Using Section 2 of the COI Disclosure form, the dean/director shall propose to the senior manager an appropriate conflict resolution plan (CRP) to resolve the conflict.  In general the CRP  should address how the required decisions will be made to avoid any conflicts.
  4. The senior manager shall determine if the proposed plan for the resolution of the conflict is within the best interest of the institution, and approve or modify the plan using Section 3 of the COI Disclosure form. The written resolution and implementation of the plan shall be communicated to the dean/director and through the supervisory chain to the employee(s) involved in the conflict of interest.
  5. The supervisor, dean/director, or provost/vice president (the first level outside of the reporting process of each person in the conflict) shall oversee the implementation of CRP.
  6. Should the conflict involve the provost or a vice president, then the actions/decision shall be directed to the president or designee.

Note:  Under no circumstances will the University approve the employment of dependent children or step-children as student employees under direct or indirect supervisory relationships.

* Senior Manager is defined as the Provost or Vice President level.

This policy was approved by the Board of Trustees on 11-09-2010.

Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on

Title: Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on
Policy Owner: Office of the Provost
Applies to: Faculty
Campus Applicability: All Campuses
Effective Date: March 25, 2015
For More Information, Contact: Office of the Provost
Contact Information: (860) 486-4037
Official Website: http://consulting.uconn.edu/

 

POLICY ON CONSULTING FOR FACULTY AND MEMBERS OF THE FACULTY BARGAINING UNIT

March 25, 2015

1. INTRODUCTION

Consulting is a time honored and frequent activity of faculty throughout U.S. research universities. The ability to consult is important in promoting recruitment and retention of faculty of the highest quality. Often, such consulting activities provide a range of benefits including fostering economic development, enhancing the reputation of the University, promoting faculty development and enhancing the faculty’s ability to bring to the classroom current and relevant “real world” experiences, among others.

Consulting is an activity performed by a faculty member for compensation as a result of his/her expertise or prominence in his/her field while not acting in his/her official capacity as a State employee (i.e. in his/her own time.)  The University’s Laws and Bylaws prohibit faculty from consulting on “time due to the University”.

2. PURPOSE

This Policy describes how members of the faculty and members of the faculty bargaining unit (both hereafter referred to as “faculty member(s)”) may participate in consulting activities while complying with the State of Connecticut Code of Ethics, the University of Connecticut Ethics Statement, the University’s Code of Conduct and the University’s Laws and Bylaws.

3. SCOPE

This policy applies to all faculty members paid by the University of Connecticut and University of Connecticut Health Center.

4. DEFINITIONS

a) consulting – providing services, advice and similar activities for compensation[1],  based on a faculty member’s professional expertise or prominence in his or her field, while not acting as a State employee.

b) contracting entity – The entity engaging and compensating the faculty member for the consulting activity.

c) ‘time due to the University’ – Any time necessary for successfully carrying out the duties assigned to and for which a faculty member was hired.  This includes both sufficient time to perform assigned duties as well as sufficient opportunity to meet with other faculty, staff and students.

d) “normal work time/days”– The usual time (days of the week, hours in the day) committed to assigned duties.

e) Compensation- compensation for services rendered include, but are not limited to, money, stock, stock options, material gifts, equity interest, other interests of value, and “luxury travel” (i.e. travel expenses in excess to what the State would have paid if the person had traveled as a State employee). Within this policy, compensation does not include royalties covered under Connecticut statutes 10a-110g (Rights as to products of authorship).

f) “a faculty affiliated company” is a company [or other legal entity] in which the faculty member, or a faculty member’s immediate family, has an ownership interest or serves on the board of directors or board of advisors.

5. POLICY

a) All faculty members, with the exception noted under ‘q’ below must receive written permission in advance from their supervisor and the Provost or Executive Vice President for Health Affairs, (whoever has jurisdiction over that member), or their designees, in order to engage in consulting activities.  Requests for such permission will describe the consulting activity, the contracting entity, the dates (or range of dates) that the activity will occur, and the maximum total effort in terms of the faculty members’ normal work days to complete the consulting activity.

b) Permission to consult may only be granted when:

i. The request to perform the consulting activity occurs due to the faculty member’s expertise or prominence in his or her field, not the faculty member’s official State position.

ii. The faculty member is currently, fully performing his/her State duties.

iii. The consulting activity will not interfere with a faculty member’s future ability to perform his/her duties.

iv. The faculty member is not competing with the University for work that may be perceived as being work the University would choose to perform.

v. Those members of a faculty bargaining unit who have specific teaching and/or research responsibilities, the consulting contributes to the continued development of the faculty member’s professional expertise or academic reputation.

c) Approvals must be obtained for each consulting activity. Any on-going consulting activity must be approved on a fiscal year basis (i.e. July 1 – June 30.)

d) The disclosure of proprietary information (i.e. intellectual property owned in part or in total by the University) is prohibited unless specific permission is granted.

e) The faculty member must inform the contracting entity that s/he is not acting as a State employee while performing the consulting activity and is not covered by any State liability protection.

f)  The faculty member may not inappropriately use his/her association with the University in connection with the consulting activity.  That is, members may identify their employee status, but they shall not speak, act, or make representations on behalf of the University or express institutional endorsement in relation to the outside activity. Further, it must be made clear that permission to use the University name, logos, or other identifiable marks may only be granted by the University.

g) Permission to use State resources while consulting must be provided in writing, in advance, and use of such resources must be fully reimbursed to the University of Connecticut.

h) When compensation would be deemed to be a ‘significant financial interest’ as defined in the Policy on Financial Conflicts of Interest in Research, the faculty member must disclose this in financial statements made under that policy.

i) The faculty member must get approval if the faculty member is working for a faculty affiliated company in a paid or unpaid capacity, including as an employee, consultant, or advisor.

j) It is in the University’s best interest to ensure that its faculty does not compete with the University for work it has or is planning to do itself by teaching a course at another institution for compensation. With this understanding, faculty members may request permission to teach elsewhere under the conditions of this policy and as long as the assignment is determined to be beneficial to the interest of the University.

k) All faculty members who were engaged in a consulting activity in a given fiscal year must complete a year end reconciliation report describing all consulting activities for which they have received approval. If the estimates regarding anticipated time spent on each activity and the compensation range provided when requesting permission to consult do not reflect what actually occurred, such information should be revised appropriately.

l) The Provost and the Executive Vice President for Health Affairs will submit annual reports of consulting activities for the faculty members under their respective jurisdictions to the Joint Audit and Compliance Committee of the Board of Trustees.

m) The University’s Office of Audit and Management Advisory Services (AMAS) shall develop and implement a plan of regularly recurring monitoring and audits to ensure the complete and accurate implementation of this policy.

n) A report or allegation of a violation or noncompliance with this policy shall be reviewed by the Provost or Provost designee.  After due process, the Provost may elect to withdraw the authorization or appropriately modify the conditions upon which the authorization to consult is granted so as to resolve any conflict.  Such actions are subject to reversal through relevant appeal procedures including those described in the University’s Bylaws.

o) Failure to comply with the provisions of this policy may result in appropriate disciplinary action, including but not limited to, loss of the privilege to engage in consulting activities or termination from service.  Such disciplinary action will be issued in accordance with the applicable provisions of the collective bargaining agreement or the employment agreement of the faculty member and subject to any appeal rights that may be available.

p) Any faculty member who does not receive prior written approval under this policy is subject to the jurisdiction of the Office of State Ethics.  In addition, the faculty member may be subject to sanctions issued by the University for violating this policy.

q) Faculty paid less than 50% time by the University of Connecticut and/or University of Connecticut Health Center do not need approval to consult.  The requirements described in 5b. ii – iv, 5d-m still apply.[2] Provisions 5b i., 5b v., 5c do not apply.

r) Faculty paid less than 50% time by the University of Connecticut and/or University of Connecticut Health Center may voluntarily elect to request prior approval to consult as described in 5a.  In such cases, all the rules under 5a-n are applicable.[3] Once such a faculty member has requested approval to consult, all subsequent consulting activities in that fiscal year must also obtain such approval.

6. CONFIDENTIAL INFORMATION

Any financial information provided in the consulting request forms or reconciliation reports will be deemed confidential financial information, in accordance with Section 1-210(b) of the Freedom of Information Act, and will not be disclosed to any third party unless the member agrees or a court of competent jurisdiction so orders, or in order to comply with Federal and/or State laws or regulations related to the handling of Federal research grants.


[1] Within this policy, compensation does not include royalties covered under Connecticut statutes 10a-110g.

[2] Per State statute, final jurisdiction whether such consulting is compliant with the State Code of Ethics resides with the Office of State Ethics for such consulting activities.

[3] Per Public Act 07-166 section 12, the University has final jurisdiction to approve such consulting activities.

 

Policy Revisions*: 3/25/2015;4/24/2013; 11/14/2012; 4/13/2011; 4/20/2010; 9/25/2007;  4/10/2007

*Approved by the Board of Trustees.

Compliance Training Policy

Title: Compliance Training Policy
Policy Owner: Office of University Compliance
Applies to: All faculty, staff, graduate assistants, and affiliates
Campus Applicability: All University campuses, including UConn Health
Effective Date: August 13, 2008
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530
Official Website: https://compliance.uconn.edu/

Purpose

As recipients of Federal funding, the University is required to provide all employees and graduate assistants (collectively “employees”) and affiliated parties with training on the elements of the University’s compliance program and the University’s expectations that all will act in accordance with applicable laws, policies, and standards.

Policy Statement

All University employees are required to receive compliance training, which may differ in type of training or frequency based on their role and responsibility. Specific training requirements are determined based on an employee’s job function at the University in conjunction with other University policies, laws and regulations.

All who are required to complete compliance trainings may be mandated to attest that they have received the training and understand its contents, including the covered resources and potential disciplinary action or sanctions as a result of any incident of non-compliance with University policies as well as applicable laws and regulations.

Employees may be required to complete specialized and/or additional compliance-related training as needed for their positions or in an effort to maintain the institutions compliance with applicable laws and policies, whether those trainings are provided by the Office of University Compliance or another University office or entity with compliance-related responsibilities.

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, and applicable collective bargaining agreements. Management, in consultation with the Department of Human Resources and in accordance with collective bargaining agreements, will be responsible for issuing appropriate disciplinary action for non-compliance.

Related Resources

Click here to identify mandatory training requirements, as well as supplemental training opportunities within UConn and UConn Health.

Policy History

Approved by the Executive Compliance Committee 8-13-2008; Revised and Approved by the University Compliance Committee on 6-11-2020 and by the UConn Health Administrative Policy Committee on 6-25-2020.

Code of Conduct

Title: Code of Conduct
Policy Owner: Office of the President
Applies to: Faculty and Staff
Campus Applicability: All Campuses
Effective Date: February 22, 2011
For More Information, Contact Office of University Compliance
Contact Information: (860) 486-2530
Official Website: https://compliance.uconn.edu/

This document serves to guide the daily operations of our University system including:

  • The Storrs campus;
  • Schools of Law and Social Work;
  • Regional campuses throughout the State;
  • UConn Health

Table of Contents

Letter from the President

Ethics Statement

Introduction

Campus-Wide Standards

Education Standards

Research Principles and Standards

Public Engagement and Outreach Standards

Patient Care Standards

Business, Fiscal and Legal Standards

External Relations and University Advancement

Resources, Additional Information, and Reporting

 

 

Letter from the President

Dear Colleagues:

The University of Connecticut is committed to assuring the highest standard of integrity in all aspects of University life and in all University and University-sponsored activities. While this goal is simply stated, its attainment requires concerted effort on the part of all members of the University community, particularly faculty, administrators and staff. Federal, state and local regulations which govern our activities are increasingly complex, and as the University’s activities expand in size, scope and prominence, it is important that all of us understand relevant policies and know what is required in terms of compliance and reporting.

The University of Connecticut Board of Trustees is the body that is ultimately responsible for ensuring full compliance. At the Board’s direction, the University has established a Compliance Program to help in our efforts to adhere to all federal, state and local regulatory requirements. A key ingredient of an effective Compliance Program is the establishment of a Code of Conduct. This Code of Conduct was developed with input from faculty, administrators and staff.

This Code serves to guide the conduct of University activities in support of the University’s mission and is designed to serve three key purposes:

  1. To set the basic standards of workplace behavior that the University expects of all faculty, administrators and staff.
  2. To state publicly the University’s long-term commitment to the highest standards of integrity in education, research,health care, public engagement and service.
  3. To assure that faculty, administrators and staff understand their shared responsibility for keeping the University in full compliance with all applicable laws, regulations and policies.

Please read the Code carefully, and take all steps necessary to apply its standards. The Office of University compliance is responsible for monitoring compliance and serving as a resource for questions and guidance on the Code, and on the University policies and procedures that spell out compliance requirements in greater detail.

A key element in assuring University-wide compliance is a system for reporting potential violations. In an institution this large and active, there may be areas of confusion; regrettably, there may also be instances in which individual behavior does not meet appropriate ethical expectations. Any University employee who observes a possible violation of law, regulation, policy or approved procedure has an obligation to report it. While a key element is reporting inappropriate activity, I want to emphasize that the most important element of any compliance or ethics program is working cooperatively to assure a positive climate of openness and integrity. Great universities function as true communities in which faculty, administrators, staff and students collaborate to achieve common goals. That holds true for instruction, research, public engagement, service and, at the most fundamental level, ethical compliance.

I want to thank you for understanding and adhering to these standards, and for your commitment to the highest level of ethical conduct in fulfillment of our institutional responsibilities.

Sincerely,
Thomas C. Katsouleas

 

The University of Connecticut Ethics Statement

The standards contained in this Code of Conduct reflect the University of Connecticut’s core values, as they have been articulated over time by generations of faculty, staff, administrators, students and the State of Connecticut. These values are essential and enduring tenets of our organization. A statement of these values, while reiterating concepts already well understood, is helpful in outlining the context in which our Code will operate. Please be advised that violation of the standards in this Code of Conduct may result in appropriate disciplinary measures up to and including dismissal.

Knowledge: Members of the University community value truth, the pursuit of truth, intellectual curiosity and academic freedom. Our faculty and students seek to create new knowledge and are committed to sharing ideas, research findings and the products of intellectual and creative pursuits with the broader community

Honesty: Members of the University community are truthful and sincere in their words and actions and do not intentionally mislead others or provide inaccurate information.

Integrity: Institutional and individual behaviors at the University reflect fundamental moral and ethical values. Our actions are beyond reproach and avoid both the fact and the appearance of impropriety.

Respect: The University honors and respects individuality and demonstrates tolerance for the personal beliefs and cultural differences of all individuals. As members of an academic community, we seek to foster a spirit of civility and collegiality through open and honest communication. We strive to protect the health, safety and well-being of all persons. We protect the private and confidential information that is provided by our patients and research participants, faculty, administrators, staff, students, volunteers and others. We value an environment that is free from harassment, intimidation, bullying, incivility, disrespect and violence.

Professionalism: The University and its members expect that the professional standards and requirements that are applicable to the academic, research, clinical, engagement, administrative and other professions comprising our community will be followed. We are responsible and accountable for our actions and are expected to make reasonable efforts to comply with all applicable federal, state and local government laws and regulations. As individuals and as an institution, we also strive to follow ethical business practices and to act as good stewards of the resources made available to us.

Introduction to the University of Connecticut Code of Conduct

In all its endeavors, the University of Connecticut is dedicated to excellence that is demonstrated through national and international recognition. As Connecticut’s public research, land-grant and sea-grantuniversity, through freedom of academic inquiry and expression, we create and disseminate knowledge by means of scholarly and creative achievements, graduate and professional education, andpublic engagement and service. Through our focus on teaching and learning, the University helps every student grow intellectually and become a contributing member of the state, national and world communities. Through teaching, research, engagement and service we embrace diversity and cultivate leadership, integrity and engage citizenship in our students, faculty, staff and alumni. As our state’s flagship public land and sea grant institution, we promote the health and well being of Connecticut’s citizens through enhancing the social, economic, cultural and natural environments of the state and beyond.

If you are faced with an ethical issue, you should consult this Code of Conduct as well as current University policies and procedures. You are responsible and accountable for addressing your ethical dilemmas. Consultation with your supervisor, other appropriate colleagues, or the Office of University Compliance is appropriate and valued.

The Code of Conduct includes “Questions to Ask Yourself” after each set of Standards. These questions are intended to be thought provoking and assist employees by providing examples of matters that each of us may face during our employment with the University. For guidance regarding individual situations that relate to any of these or other questions, please feel free to contact the Office of University Compliance.

Campus-Wide Standards

The University of Connecticut values all members of its community and recognizes that each person contributes to the overall success of the institution. The University further recognizes that it is through the efforts of its faculty, administrators and staff that it achieves national and international prominence and delivers a world class education to its students. The culture of the University is one of respect, civility, trust, cooperation and collaboration among all its members. We believe all members of the University community are entitled to an environment that ensures collegiality and mutual respect.

Conduct of Faculty, Administrators and Staff

  • Members of the University community shall perform their duties in a fair and ethical manner in accordance with established policies, procedures and regulations.
  • Members of the University community shall carry out their duties with professionalism. The University supports the efforts of its faculty, administrators and staff to achieve and maintain professional standards.
  • The University provides equal opportunity and access to its employment, programs, benefits and services.
  • Supervisors have a particular responsibility to support the Code of Conduct and to demonstrate compliance within their units.
  • Relationships of an inappropriate personal nature between supervisors and those they supervise are prohibited.

Civility

  • The University values an environment that promotes a spirit of civility and collegiality, while fostering open and constructive intellectual debate.
  • All members of the University community have a responsibility to treat each other with consideration and respect. Managers and supervisors have an elevated responsibility to demonstrate these behaviors and support their expression in the workplace.
  • Engaging in behaviors that harass, intimidate, bully, threaten or harm another member of the University community does not support a respectful and civil work environment.

Non-Discrimination

  • The University encourages and respects diversity within the university community and does not allow discrimination on the basis of age, race, national origin, religion, disability, sex, sexual orientation or any other characteristic protected by law in any activity or operation of the institution.

Harassment

  • The University affirms its dedication to foster a community that condemns all forms of discrimination or acts of intolerance including sexual harassment, intimidation and retaliation.

Confidentiality

  • Confidentiality of faculty, staff, patient and student records is respected and maintained in accordance with University policies and procedures, federal laws and state regulations. We use such records for legitimate purposes only and in accordance with proper authorization.

Computer/Telecommunications Use

  • The University’s computer and telecommunication networks are University resources that are provided to employees, students and volunteers to allow them to carry out the functions of the institution. Those who use the computer and telecommunication networks are responsible for the appropriate use of these resources. We understand, support and abide by the policies concerning the ethical and responsible use of computers and electronic information at the University of Connecticut.

Regulatory Compliance

  • The University of Connecticut Office of University Compliance strives to ensure that we meet the highest possible standards where relevant federal, state and local regulations, laws and guidelines are concerned. This office supports ethical conduct by all faculty, administrators and staff and requires ongoing monitoring of policies, procedures and practices. Education is a key component of this program.

Health and Safety

  • We are responsible for complying with all workplace safety and health regulations and will report unsafe conditions, equipment or practices to appropriate University officials, as required by law.

Conflict of Interest

  • We, as employees of the State of Connecticut, adhere to the guidelines set forth in the Connecticut Code of Ethics for Public Officials, as well as the University’s Guide to the State Code of Ethics.
  • We will not engage in outside activities which will create an actual conflict of interest and will strive to avoid the appearance of a conflict. If faced with a potential conflict of interest, members of the university community shall disclose the nature of the conflict to the appropriate parties.
  • We do not accept gifts, including food and beverage, from vendors, lobbyists or any other person or entity that is doing business with or seeking to do business with the University unless permitted under the Connecticut Code of Ethics for Public Officials.
  • We do not accept secondary employment that will impair our independence of judgment as to our official duties or which will require us to disclose confidential information.
  • We will not use our state positions for personal financial gain beyond our official compensation, or for the financial benefit of our family members or domestic partners.
  • We will not use state resources for personal use or for use unrelated to our University responsibilities.

Questions to Ask Yourself

  • Have I treated others as they wish to be treated?
  • Do I make discriminatory and harassing statements?
  • Have I used my position to intimidate or isolate others?
  • As a faculty member or staff member, should I accept a gift from a student?
  • Do I frequently use my university telephone for personal phone calls?
  • Do I use my contacts at the University to help my outside business?
  • Do my outside professional activities create an appearance of a conflict of interest?
  • Do I maintain appropriate professional relationships with students, colleagues, patients, clients and customers?
  • Have I used my position to gain employment for a family member?
  • Even if I have access to certain records, do I have the authority to view them and/or distribute them to others?
  • Do I know what to do if I think that a University record have been accessed inappropriately by someone inside or outside the University?
  • Do I take shortcuts that create a safety hazard?

Education Standards

The University of Connecticut recognizes education as one of its primary missions and strives to maintain a professional environment conducive to the development of its students. To that end, the University believes that the purposes of an educational institution are best served by attracting and developing scholars of proven professional and personal competence and integrity and by assuring those teachers and scholars freedom to expand human knowledge and understanding.

  • We educate students from a wide range of backgrounds and respect differences in each individual’s heritage and goals.
  • We respect the individual choices that students make for career paths.
  • We respect each student as a valuable individual regardless of age, race, color, nationality, ethnicity, ancestry, marital status, gender, disability, religion, sexual orientation or personal beliefs.
  • We acknowledge and support students’ rights to question faculty members, the administration and staff in good faith.
  • We comply with all applicable statutes and regulations.

Student conduct is governed by the applicable codes of conduct and professional standards of conduct adopted by their schools. While this Code applies primarily to faculty, administrators and staff, its underlying principles are, however, common to codes and regulations governing students.

Athletics

The Division of Athletics operates a broad-based program of intercollegiate athletics and recreational and intramural opportunities that reflect the ethical philosophy of the University, the interest of the student body and the desires of the University’s internal and external constituencies.

  • We offer student-athletes the opportunity to excel in academic achievement and athletic accomplishments.
  • We foster among our students a sense of citizenship, leadership and social responsibility and encourage adherence to the highest standards of integrity and ethics.
  • We promote principles of good sportsmanship, honesty and fiscal responsibility in compliance with University, state, National Collegiate Athletic Association (NCAA) and conference regulations.
  • We promote and support the University’s comprehensive commitment to diversity and equity, providing equitable opportunity for all students and staff, including women and members of minority groups.

Questions to Ask Yourself

  • Do I foster an environment that is conducive to learning?
  • Am I providing each student an equal opportunity to learn?
  • Do I react negatively when students challenge or critique my interpretation of source material?
  • Do I protect the privacy of each student’s academic record and personal information?
  • Are my grading practices fair and understood by all of my students?
  • Do I regularly update my teaching materials?
  • Am I a role model for my students regarding professional values?
  • Do I acknowledge and support providing student athletes equitable and appropriate opportunities to excel in academic achievement?

Research Principles and Standards

The University of Connecticut is committed to the highest standards of professional conduct and integrity in research. These standards include honesty, trustworthiness, objectivity, accountability, openness, respect and fairness when dealing with other people, a sense of responsibility towards others and loyalty to the ethical principles espoused by our institution.

The University expects these standards to be maintained by all academic, research and relevant support staff, students and their supervisors and other individuals conducting research or involved in the peer review process within or on behalf of the University. Prompt reporting to the appropriate institutional administrative committees of violations of human subjects’ protection, laboratory safety, or humane treatment of animals is expected.

We understand that academic freedom is essential to creating an atmosphere in which scholarship flourishes. Promotion of intellectual freedom is consistent with assuring a climate of integrity and the University has the right and the obligation to inquire into all instances of alleged or apparent misconduct in scholarly activities.

Scholarly Integrity

  • We properly collect, record and maintain research data.
  • We take responsibility for all publications and presentations of which we are author or co-author.
  • We appropriately acknowledge, in publications and presentations, those who have contributed to our research.
  • We grant access to our research data to co-investigators involved in generating the data.
  • We grant reasonable access to our research equipment and resources to other University investigators involved in research.
  • We, the University and its faculty, administrators and staff, do not interfere with the research conducted by students or faculty.
  • We do not tolerate plagiarism, falsification, or fabrication of research data, or other scientific misconduct.

Human Research

  • We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, when performing studies involving human subjects.
  • We respect human research participants and are committed to their safety.
  • We protect human subjects by securing institutional review and approval for any research.
  • We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
  • We engage all human subjects, or their appropriate representatives, before initiating a research protocol, in a meaningful informed consent process including explanations of possible risks and benefits.
  • We allow potential or current participants to withdraw from a study at any time without prejudice.
  • We notify human subjects in a timely fashion of any serious adverse events associated with a human subjects study.
  • We conduct appropriate education and training before initiating a human subjects study.

Animal Research

  • We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, regarding the care, transport, maintenance and use of animals.
  • We are committed to the humane treatment of animals in research.
  • We protect research animals by securing appropriate institutional review and approval for any research.
  • We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
  • We conduct appropriate education and training before initiating animal research.

Laboratory Safety

  • We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, concerning laboratory safety.
  • We seek prior approval of appropriate University committees when research involves hazardous chemical substances, bio-hazardous materials or radioactive materials.
  • We properly document, store, handle, transport and dispose of radioactive, bio-hazardous and hazardous chemical materials, pharmaceuticals and investigative drugs.
  • We participate in appropriate education and training before initiating studies involving such materials.
  • We comply with all workplace safety and health regulations and will report unsafe conditions, equipment or practices to our supervisors or other appropriate University officials.
  • We attend required instructional and training sessions when dictated by funding or oversight agencies.

Research Support

  • We use research funds only for their designated purposes.
  • We accurately account for time and effort related to research funding.
  • We disclose financial conflicts of interest to University administrators and, as appropriate, manage such conflicts in accordance with existing policies and procedures.
  • We properly acknowledge sponsorship of research in our publications and presentations.

We disclose inventions produced from our research to the University so that consideration is given to the protection of intellectual property.

Questions to Ask Yourself

  • Do I work safely in the lab?
  • Have I received training and approval to use research materials?
  • Have I collected data and documented my research accurately?
  • Did I face a conflict of interest today? Does it bias my research?
  • Do I protect the safety and well-being of my human or animal subjects?
  • Did I obtain proper consent from my human subjects?
  • Do I respect the privacy of research participants? Do I appropriately protect the confidentiality of their research data?

Public Engagement and Outreach Standards

The primary purpose of public engagement is to serve external constituents in a manner that leads to enhanced teaching and research. Public engagement efforts impact on the reputation of the University. Engaged scholarship, as a component of public engagement, results from public engagement and outreach. It focuses on those activities that promote advanced understanding and creative works in a mutually beneficial manner. Public engagement, which includes outreach and public service, consists of all activities where the University offers its resources, both human and physical, to external constituencies in such a manner where there is a partnership or that engaged scholarship results. These efforts are on behalf of the public good and not for private gain. The term University resource refers to those activities and entities that the University makes available to its various constituencies which may involve a cost to access.

As a land and sea grant university, the University of Connecticut is committed to our mission that includes public engagement as measured by the impact of teaching and research on the world outside of the insitution. In the spirit of true partnership, we seek to expand our interactions with groups beyond our campuses in areas of mutual concern and enhance their access to the resources available at the University. In addition to collaborations in the arts and humanities, we encourage constructive partnerships in new areas of interdisciplinary excellence, such as Health and Human Behavior, the Environment, and Human Rights. Through broadened access and reciprocal interaction, we realize synergistic outcomes that further strengthen the University and benefit the people of Connecticut as well as those beyond the state borders.

  • We believe the reputation of the University is tied to its responsiveness to the needs of the citizens and communities of the State.
  • We reach out to and engage communities in reciprocal partnerships.
  • We are respectful of our community members, demonstrate cultural competence in their interactions, and comply with University policies while engaged in and with communities, just as we would on campus.
  • We strive for responsible engaged scholarship and community-based programs to the benefit of communities by involving our partners in the planning, execution, and dissemination of the knowledge gained by such programs.
  • We translate and disseminate research results to real world applications to address problems.
  • We recognize and respect the knowledge and behaviors of our partners as we work in a collaborative environment.
  • We effectively communicate these standards and values with the organization.
  • We actively engage students in community experiences as part of our service learning priority.

Practical Considerations for Public Engagement and Outreach Principles and Standards

  • Have I ensured that the public engagement effort is consistent with the University’s mission and vision?
  • How do I solicit input regarding community needs when designing, planning, and conducting my engaged scholarship or community-based project?
  • How can I work with community members as equal and collaborative partners in all phases of the project, from planning to dissemination of findings, and avoid the perception of using the group for my gain?
  • How do I handle the findings of my work to ensure confidentiality when appropriate?
  • Am I culturally sensitive to the diverse needs of community members and partners, starting with the selection and training of my University team members?
  • How can I prioritize considerations of diversity when designing, planning, and conducting my community-based research or program, identify any barriers to participation, and work to ameliorate or eliminate such barriers?
  • How will my actions reflect how the University is viewed in the community?
  • How do I manage, use and share resources of the University in a manner that is respectful to partners?
  • How do I teach and engage my students in the work of the community as they apply classroom learning to real world situations?

Patient Care Standards

Clinicians associated with the UConn Health, Storrs and regional campuses and other University health care facilities provide compassionate primary and specialty health care in an academic environment. We focus on delivering quality patient care and fostering continuous improvement through scientific knowledge that is shared with patients, colleagues and the public.

  • We, each faculty and staff member involved in patient-related activities, are expected to understand and support the applicable Patient’s Bill of Rights and Responsibilities.
  • We strive to deliver health care that is based on contemporary scientific knowledge and technology.
  • We provide educational resources and opportunity for consultations with other health care programs to assist our patients in the planning of their treatment.
  • We strive to consider the physical, emotional and spiritual needs of our patients in making our treatment recommendations.
  • We do not extend or receive payments or benefits in exchange for referrals. Our health care and referrals are based on the well-being of and best treatment for our patients.
  • Patients have a right to ask members of their health care team about the role of students and residents in their care and to receive complete and accurate information.We explain to our patients the importance of the educational mission at the University as it relates to their treatment.
  • We provide our patients with information necessary to make informed health care decisions. This includes reviewing medical findings with each patient, as well as discussing alternative treatment options and the associated risks and benefits.
  • We prepare clear, honest and accurate patient medical documentation in a timely manner. We maintain the confidentiality of this information in accordance with existing University policies and procedures, federal laws and state regulations, including but not limited to the Health Information Portability and Accountability Act (HIPAA).
  • We provide clinical facilities and laboratories to support quality care for our patients. We adhere to appropriate policies and procedures to ensure that we retain certification in all aspects of program function as required by institutional, state and federal regulatory agencies.

Questions to Ask Yourself

  • Do I demonstrate respect and compassion for my patients and their families?
  • Was the care that I provided today in the best interest of my patients?
  • Did I answer my patients’ questions to the best of my ability or assist them in obtaining the information they requested?
  • Do I offer all of the needed resources and services to my patients or assist them in making a referral to obtain those services?
  • Do I respect the privacy of my patients and protect the confidentiality of their health information?
  • Did I document my patient care thoroughly and accurately today?

Business, Fiscal and Legal Standards

The University of Connecticut adheres to established business standards in its conduct as an institution of higher education and as a health care provider. We comply with all applicable federal, state and local government laws and regulations and strive to follow ethical business practice standards. We endeavor to conduct all University business with honesty, integrity, accuracy and fairness.

Contracts

  • We strive to make all purchasing decisions based on the best interests of and value to the University. The University follows fair business practices in its contracting.
  • We recognize the value of obtaining competitive bids when appropriate, maintaining independence, ascertaining the financial and legal status of vendors and obtaining clear written agreements for services or goods to be purchased.
  • We comply with all state guidelines regarding procurement activities. We comply with all laws relating to pricing, competition and business arrangements.

Proprietary information

  • In the course of doing business, the University creates and receives information that could directly affect the success of its business ventures or those of its current or prospective business partners. If used inappropriately, this information could unduly benefit individuals who have access to such information. The University depends on the ethical business practices and personal integrity of its employees to protect this information from premature or improper use and disclosure.

Physical property and intellectual property, including data

  • The University’s physical property includes property that is owned by the University but entrusted to individuals or organizational units within the University. Examples include office and departmental equipment and supplies, vehicles, facilities, cash, reports and records, including clinical and billing records in department offices, computer software, electronic files and data, patents, trademarks and service marks.
  • We utilize such resources properly and protect property against loss, theft, misuse and waste.
  • Research materials, inventions or devices developed through the use of University resources are the property of the University. Rights to such property may be transferred to other parties (such as commercial sponsors) only with express written authorization. Materials subject to copyright are generally not the property of the University.
  • Research data are considered the property of the principal investigator or the joint property of collaborating individuals when research data are generated by a principal investigator working in collaboration with one or more faculty colleagues. Research data generated by postdoctoral fellows, graduate students, research trainees or others who have had significant intellectual input, shall be considered the joint property of the collaborating individuals.
  • The use of any form of intellectual property covered by copyright and license agreements and used for face-to-face, distance teaching purposes or a combination of the two, will comply with copyright law and the terms of the license agreement under which it was obtained. Examples include books, journal articles, newspapers, images, audio, and video in physical or electronic form owned or borrowed by the University or the instructor.

Financial Records and Funding Sources

  • We understand that the federal and state governments constitute major funding sources for the University in student financial aid, research and other areas. As such, we acknowledge responsibility for the stewardship of such funds, understanding and complying with federal and state laws and regulations.
  • We maintain accurate and timely financial records in accordance with the University’s policies and Generally Accepted Accounting Principles. We use appropriate internal financial controls to safeguard assets and to ensure compliance with all internal and external accounting rules and regulations. We cooperate fully with internal and external auditors and regulatory agencies during examinations of all books and records and do not alter or destroy any documents in anticipation of such reviews.
  • We, as employees of the University, accurately account for our time and properly document when seeking reimbursement for work-related expenses.
  • We charge and bill for patient care services in accordance with third party regulations and applicable state and federal laws. We bill for medically appropriate services that are clearly and accurately documented in the medical record. We submit claims for services in a timely manner. We maintain accurate patient accounts and promptly correct billing errors.
  • We acknowledge that clinical care providers, coding personnel and billing staff have a collective responsibility to understand the third party regulations and federal and state laws governing the services they are providing.

Questions to Ask Yourself

  • Did I document my work clearly, honestly and accurately?
  • When I sign a document do I understand what I am signing?
  • Do I understand when the competitive bidding process must be used?
  • Have I signed a contract without obtaining proper authorization?
  • Am I wasteful of university supplies?
  • Was I honest with my coding of patient visits today?
  • Do I share my computer password with others?

External Relations and University Advancement

Government relations and political activity

  • We depend, as a public institution, upon the support and trust of federal and state officials.
  • We will not make representations on behalf of the University without official authorization.
  • We do not engage in partisan political activities while on state time nor will we use University resources for the purposes of influencing a political election.
  • We adhere to federal and state laws which provide guidance for the political activities of the University employees.

Public access to University information

  • We facilitate accurate, ethical and timely news coverage of significant programs and the achievements of faculty, administrators, staff, students and alumni.
  • We comply with all federal and state laws and regulations as well as all University polices regarding the release of information about activities of the University, or its employees, students, volunteers, patients or research subjects, carefully balancing privacy rights with the public’s interest.

University Advancement

  • We recognize that the process of raising charitable funds requires ethical and sensitive interactions with prospective and current donors. Although we may release general information about alumni or other supporters, we respect an individual donor’s intent and honor all requests for anonymity.
  • We recognize that the primary responsibility for development of prospective donors lies with the University of Connecticut Foundation. The Foundation staff works in cooperation with offices and departments across the University but which is organizationally independent of the University itself.

Media Relations

  • We acknowledge that University Communications is the University’s primary and official liaisons to the news media – international, national, regional, state and local – and that this department is responsible for initiating, developing and maintaining effective, productive and beneficial relations with the news media in communicating University news and in responding to media requests.
  • We respect the individual freedom of faculty, staff and administrators to express their personal opinions on University actions and policies, while also recognizing that University Communications is responsible for coordinating official University comment on all matters regarding the institution.
  • We understand that the University encourages its faculty, staff and administrators to serve as members of community panels, boards, civic organizations, professional associations and other similar voluntary associations. An employee assuming such a role is not acting as a spokesperson of the University.

Graphic Standards

  • We recognize that University Communications is responsible for establishing and maintaining the University’s graphic standards and that specific standards apply to the use of the University’s logos and seals.
  • We understand that the University has legal rights regarding the use of its name, logos and seals and protected trademarks.

Questions to Ask Yourself

  • Have I referred media requests to University Communications?
  • Should I talk “off the record” to a reporter?
  • When is it appropriate to talk to the media about my research or to comment on the research of others?
  • Should I speak on behalf of the University to government officials regarding University mattersCan I be identified as a University employee in my political or charitable activities?
  • Do I maintain clear boundaries between my professional role and my personal activities that are unrelated to the University?

Resources, Additional Information and Reporting

The University has established the Office of University Compliance and Office of Audit & Management Advisory Services to oversee its internal audit and compliance programs and to ensure compliance with applicable laws, regulations, policies and procedures.

Obtaining Additional Information, Reporting Compliance Concerns and Non-retaliation Policy

  • For additional information please refer to the appropriate website or contact the office at the phone numbers or email addresses noted below. If you wish to report suspected violations of laws, regulations, rules, policies, procedures, ethics or any other information you feel uncomfortable reporting to your supervisor or faculty administrator you may also contact the Office of University Compliance directly using the phone numbers or email addresses listed below.
Storrs and Regional Campuses:

Website: https://compliance.uconn.edu/
Phone: (860) 486-2530

Fax: (860) 486-4527

UConn Health:

Website: https://compliance.uconn.edu/ 
Phone: (860) 679-1969

  • If you wish to report a concern or a suspected violation anonymously you may contact the University’s REPORTLINE using the contact information below. The REPORTLINE is operated by a private (non-University) company. No effort is made to identify the person reporting and no trace of the call is performed. Information received is given to the Compliance Officer for appropriate action. This service is available 24 hours a day, 7 days a week and is staffed by independent specialists trained to obtain complete and accurate information in a confidential manner. If you wish, you may obtain information about the Compliance Office response to your call by following up with the REPORTLINE at a later date. To contact the REPORTLINE:
Storrs and Regional Campuses Phone: 1-888-685-2637 UConn Health Phone: 1-888-685-2637
Web reporting address: https://www.compliance-helpline.com/uconncares.jsp

Other Reporting Options

  • State Auditors of Public Accounts

The Whistle Blower Act, Section 4-61dd of the Connecticut General Statutes, authorizes the Auditors of Public Accounts to receive information concerning matters involving corruption, unethical practices, violation of State laws or regulations, mismanagement, gross waste of funds, abuse of authority or danger to the public safety occurring in any State department or agency. Upon receiving such information the Auditors are required to review such matter and report their findings and any recommendations to the Attorney General.The Auditors shall not, after receipt of any information from a person under the provisions of this section, disclose the identity of such person without his/her consent unless the Auditors determine that such disclosure is unavoidable during the course of the review. You can file a complaint with the Auditors of Public Accounts by calling (860) 566-1435 or toll free at (800) 797-1702. Website: https://www.cga.ct.gov/apa/

  • Federal False Claims Act (31 U.S.C. § 3729-3733)

This act permits a person with knowledge of fraud against the federal government to file a lawsuit on behalf of the government against those that committed the fraud. The person filing the lawsuit is also known as the “whistleblower” or “qui tam” plaintiff. The “qui tam” plaintiff must notify the United States Department of Justice (DOJ) of all information regarding the fraud. If the DOJ takes the case and fraud is proven the “qui tam” plaintiff is entitled to a portion of the money recovered by the federal government. Under the False Claims Act the “qui tam” plaintiff is protected from retaliation that may result from his or her involvement in the case. This is known as Whistleblower Protection.

 

Non-Retaliation

  • University policy prohibits retaliation if you report in good faith a compliance concern to any supervisor, faculty, administrator, the Compliance Office, the REPORTLINE orany appropriate agency outside of the University. If you feel that you have been subject to retaliation, you should contact the Compliance Office immediately. The Compliance Office will respond to all reports in a timely manner in order to resolve any non-compliance and to educate regarding compliance concerns.

 

Policy Created*: April 11, 2006

Policy Revisions*: 2/22/2011

*Approved by the Board of Trustees.