RL-1

Review List 1

Human Subjects Research

Posted on by
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

Posted on by
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

General Rules of Conduct

Posted on by
Title: General Rules of Conduct
Policy Owner: Human Resources
Applies to: Faculty, Staff
Campus Applicability: Storrs and Regional Campuses
Approval Date February 27, 2024
Effective Date: February 29, 2024
For More Information, Contact Labor Relations
Contact Information: (860) 486-5684 or laborrelations@uconn.edu
Official Website: https://hr.uconn.edu/employee-relations/

PURPOSE

To outline expectations for employee conduct in the workplace.

POLICY STATEMENT

The University requires employees to adhere to the General Rules of Conduct and will hold employees accountable for violations.  A supervisor’s failure to enforce a rule does not excuse employees from complying with it, nor does it prevent the University from taking disciplinary action thereafter. The below list is not exhaustive and other, more detailed policies on these topics remain in effect. Nothing in this policy constrains the University from pursuing criminal prosecution, if applicable, in addition to dealing with or responding to issues administratively.

The General Rules of Conduct prohibits the following:

  1. Unlawfully distributing, selling or offering for sale, possessing, using, or being under the influence of alcohol, drugs, or controlled substances (including marijuana) when on the job or subject to duty;
  2. Misusing or willfully neglecting University property, funds, materials, equipment, or supplies;
  3. Fighting, engaging in unruly or disruptive behavior, or acting in any manner which endangers the safety of oneself or others. This prohibition includes but is not limited to acts of aggression, intentional or not, as well as threats of violence;
  4. Marking or defacing walls, fixtures, equipment, machinery, or other University property, or willfully damaging or destroying property in any way;
  5. Interfering in any way with the work of others;
  6. Stealing or possessing without authority any equipment, tools, materials, or other property of the University, or attempting to remove them from the premises without written permission from the appropriate authority;
  7. Being inattentive to duty, including but not limited to sleeping on the job;
  8. Refusing to do assigned work or to work overtime if directed, working overtime without proper authorization, or failing to carry out the reasonable directive of a manager, supervisor, or department head;
  9. Falsifying any time card, attendance report, or other University record, or giving false information to anyone whose duty it is to make such record;
  10. Being repeatedly or continuously absent or late, being absent without notice or reason satisfactory to the University, or leaving one’s work assignment without authorization;
  11. Conducting oneself in any manner, which is insulting, intimidating, threatening, physically or verbally abusive, or contrary to common decency or morality; making verbal or written remarks that are inflammatory, derogatory, discriminatory, harassing, or that create a hostile work environment;
  12. Carrying out any form of harassment, including sexual harassment;
  13. Operating state-owned vehicles or private vehicles for state business without proper license, or operating any vehicle on University property or on University business in an unsafe or improper manner;
  14. Having an unauthorized weapon on University property;
  15. Appropriating state or University equipment or resources for personal use or gain or appropriating state, University, student or employee time or effort for personal use or gain;
  16. Engaging in actions which constitute a conflict of interest with one’s University job; including but not limited to, in the case of academic administrators and faculty, the teaching of credit courses at other educational institutions, unless approved in advance in accordance with established procedures;
  17. Gambling or unauthorized solicitation;
  18. Smoking or vaping within no-smoking areas;
  19. Computer abuse, including but not limited to plagiarism of programs, accessing or viewing obscene or pornographic material, misuse of computer accounts, unauthorized destruction of files, creating illegal accounts, possession or use of unauthorized passwords, disruptive or annoying behavior on the computer, and non-work-related use of computer software and hardware;
  20. Being convicted of a crime;
  21. Engaging in activities which violate either the State’s or the University’s Code of Ethics;
  22. Engaging in activities which are detrimental to the best interests of the University or the State;
  23. Entering, using, or providing access to the worksite other than for work purposes or to unauthorized individuals;
  24. Retaliating in any form or manner toward an employee or student for reporting a violation of any federal or state statute or regulation or University rule or policy;
  25. Engaging in any form of sexual or unwelcome physical contact in the workplace;
  26. Failing to cooperate or being untruthful in a University investigation.

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.  When applicable, individuals may also be held accountable under the Student Code of Conduct.

PROCEDURES/FORMS

None

REFERENCES

Supervisors should contact Labor Relations at 860-486-5684 or laborrelations@uconn.edu regarding any suspected violation of the General Rules of Conduct.

POLICY HISTORY

Policy created: January 2004

Revisions: February 27, 2024 (Approved by the Senior Policy Council and the President)

Financial Conflicts of Interest in Research

Posted on by
Title: Financial Conflicts of Interest in Research
Policy Owner: Vice President for Research
Applies to: Faculty, Staff, Students
Campus Applicability: Storrs and Regional Campuses
Approval Date: January 30, 2023
Effective Date: January 30, 2023
For More Information, Contact Director, Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: https://ovpr.uconn.edu/services/rics/fcoi/

BACKGROUND

Investigators at the University of Connecticut (University) promote the research mission of the University relating to the discovery and dissemination of knowledge that emerges from that research. Participation in activities of professional associations, industry collaborations, and other public and private entities can assist in meeting these expectations, while also serving the academic interests of the University. In addition, such participation brings enhanced national and international status to the University and the State. Over the past decade, the opportunity for University faculty and staff to engage in external professional and entrepreneurial activities has increased markedly, and is encouraged by the state and federal governments because of the resulting economic development benefits. The State of Connecticut has determined that the commercialization of University research and technology transfer is critical to Connecticut’s long-term economic growth.

However, it is vital that Investigators adhere to state and federal regulations dealing with avoiding and managing potential and existing conflicts of interest. In order for the University to maintain public   trust and support in carrying out its mission, including all sponsored activities, the University must demonstrate that it subjects itself to the highest standards of ethical behavior.

PURPOSE

This Policy on Financial Conflicts of Interest in Research (Policy) provides guidelines to promote objectivity in research. The Policy establishes standards to ensure that the design, conduct, and reporting of research funded by extramural sponsors will not be biased by any conflicting financial interest of an Investigator. The University encourages Investigators to engage in appropriate outside relationships, but significant financial interests related to these relationships need to be disclosed, reviewed, and managed in accordance with this Policy.

APPLICABLE FEDERAL REGULATIONS

The following federal regulations inform this policy:

Department of Energy (DOE) Interim Conflict of Interest Policy
https://www.energy.gov/sites/default/files/2022-10/Department%20of%20Energy%20Interim%20Conflict%20of%20Interest%20Policy.pdf

Public Health Service (PHS)
https://grants.nih.gov/grants/policy/coi/index.htm

National Science Foundation (NSF)
http://www.nsf.gov/pubs/policydocs/pappguide/nsf10_1/aag_4.jsp

Food and Drug Administration (FDA)
https://www.fda.gov/RegulatoryInformation/

In summary, the federal policies and regulations stipulate:

  1. Disclosures of significant financial interests by ALL Investigators;
  2. Institutional certification that all proposed and ongoing sponsored research is either free of financial conflicts of interest, or that such conflicts are managed, reduced or eliminated, and reported as required by applicable regulations;
  3. The implementation of an institutional mechanism for managing financial conflicts of interest in research;
  4. Notification of sponsors, as required, of management plans and if the University is unable to manage financial conflicts of interest satisfactorily;
  5. Monitoring of compliance, procedures for retroactive review in cases of non-compliance, enforcement mechanisms, and sanctions where appropriate;
  6. Maintenance of records relating to this policy for at least three years following the termination of a given project; and,
  7. Providing information and training to Investigators, as required by applicable regulations.

DEFINITIONS

Business: any corporation, partnership, sole proprietorship, firm, franchise, association, organization, holding company, joint stock company, receivership, business or real estate trust, or any other legal entity organized for profit or charitable purposes.

Clinical Investigation(PHS): any experiment in which a drug is administered or dispensed to, or used, involving one or more human subjects. An experiment here is any use of a drug, except for the use of a marketed drug in the course of medical practice.

Clinical Investigation (FDA): any experiment that involves a test article and one or more human subjects, and that either is subject to requirements for prior submission to the Food and Drug Administration under section 505(i) or 520(g) of the act, or is not subject to requirements for prior submission to the Food and Drug Administration under these sections of the act, but the results of which are intended to be submitted later to, or held for inspection by, the Food and Drug Administration as part of an application for a research or marketing permit. The term does not include experiments that are subject to the provisions of part 58 of the chapter, regarding non-clinical laboratory studies.

Financial Conflict of Interest (FCOI):  a situation in which significant financial interests in a business, or other personal considerations provided by a business, may compromise, or have the appearance of compromising, an Investigator’s professional judgment in conducting or reporting research, the results of which could affect the aforementioned business, either directly or indirectly. An FCOI exists when the University, through its designated official(s), reasonably determines that an Investigator’s Significant Financial Interest is related to a research project and could directly and significantly affect the design, conduct or reporting of the research.

Human Subject (PHS regulations “Protection of Human Subjects” 45 CFR Part 46, as administered by OHRP): a living individual about whom an Investigator conducting research obtains data  through intervention or interaction with the individual, or identifiable private information.

Human Subject (FDA regulations 21 CFR 50): an individual who is, or becomes, a participant in research, either as a recipient of the test article or as a control. A subject may be either a healthy human or a patient.

Immediate Family: the Investigator’s spouse/domestic partner and dependent children.

Institutional Responsibilities: an Investigator’s professional responsibilities on behalf of the University, which include research, teaching, and service as, e.g., outlined in the Policy on Faculty Professional Responsibilities (http://policy.uconn.edu/?p=659).

Intellectual Property: a product of the intellect that has commercial value, including copyrighted works, patents, business methods, and industrial processes.

Investigator: the principal investigator and any other person (regardless of title or position) who is responsible for the design, conduct or reporting of research or educational activities*. This may include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists engaged in research conducted at the University) as well as consultants.

*For DOE funded projects, the definition states that the Principal Investigator or any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project.

Research (PHS regulation 45 CFR 46.102(d)): a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge. Activities which meet this definition constitute research for purposes of this Policy, whether or not they are conducted or supported under a program which is considered research for other purposes.

Significant Financial Interest (SFI):

  1. Significant Financial Interest means:
For DOE, PHS and all sponsors that follow the 2011 PHS FCOI Regulations[1] For NSF and all other sponsors:

 
With regard to any publicly traded entity, an SFI exists if the value of any remuneration[2] received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000; or

 

With regard to any non-publicly traded entity, an SFI exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or  when  the  Investigator  (or the Investigator’s Immediate Family) holds any equity interest(e.g., stock, stock  option,  or other ownership interest); or

 

Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.

 

 An equity interest that when aggregated for the Investigator and the Investigator’s Immediate Family exceeded $5,000 over the last 12 months, and/or is expected to exceed $5,000 in value over the next 12 months as determined through reference to public prices or other reasonable measures of fair market value; or when the Investigator (or the Investigator’s Immediate Family) holds a 5% or greater equity interest (e.g., partnership, ownership, stock, stock option, or other ownership interest) in a single publicly traded entity or holds any equity interest in a non-publicly traded entity; or

 

Salary, royalties or other payments not from the University for services (e.g., consulting fees or honoraria) that when aggregated for the Investigator and the Immediate Family over the last 12 months exceeded $5,000 or are expected to exceed $5,000 over the next 12 months;

 
Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their Institutional Responsibilities.

 
  1. In addition, the following needs to be disclosed for Clinical Investigations covered by FDA regulations:
    1. Compensation made to the Investigator in which the value of compensation could be affected by the outcome of the study/research project.
    2. A proprietary interest in the tested product, including, but not limited to, a patent, trademark, copyright or licensing agreement.
    3. Significant payments of other sorts, which are payments that have a cumulative monetary value of $25,000 or more made by the sponsor of a covered study to the investigator or the investigators’ institution to support activities of the investigator exclusive of the costs of conducting the clinical study or other clinical studies, (e.g., a grant to fund ongoing research, compensation in the form of equipment or retainers for ongoing consultation or honoraria) during the time the clinical investigator is carrying out the study and for one year following completion of the study.
  2. Department of Energy
    1. For each disclosure investigators will comply with the DOE specific certification statement requirements.
  1. The term Significant Financial Interest does not include the following types of financial interests:
      1. Salary, royalties, or other remuneration paid by the Institution to the Investigator if the Investigator is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights;
      2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles;
      3. Income from seminars, lectures, or teaching engagements sponsored by a  federal,  state,  or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education;**; or
      4. Income from service on advisory committees or review panels for a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.**
      5. Travel that is reimbursed or sponsored by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center,** or a research institute that is affiliated with an Institution of higher education.

    ** Department of Energy policy does not exclude academic teaching hospitals or medical centers for letters c, d and e above.

Sponsor: an individual company, or any entity which takes responsibility for the initiation, management, and/or financing of a research project, but which does not actually conduct the investigation.

PROCEDURES

I. Notification

A copy of this policy will be sent to all current Investigators and will be provided to all new Investigators upon hire. The policy is also available on the UConn website under “University Policies.”

II. Training

All PHS-funded and DOE- funded Investigators must complete training prior to engaging in PHS or DOE funded research and at least every four years thereafter as well as under the following circumstances (in the timeframes noted in parentheses):

  1. The University’s Financial Conflict of Interest policy changes such that Investigator requirements are affected (within 60 days).
  2. An Investigator is new to the University (prior to engaging in PHS or DOE funded research).
  3. The University finds that an Investigator is not in compliance with the Policy or a management plan, as applicable.

III. Disclosure of Significant Financial Interests

Each Investigator must disclose his/her known SFIs (including those of the Investigator’s Immediate Family) that reasonably appear to be related to the Investigator’s Institutional Responsibilities, or that would reasonably appear to be affected by the research for which funding is sought or are in entities whose financial interests would reasonably be affected by the research. In determining whether a financial interest has to be disclosed, the Investigator shall consult the definition of SFI within this policy and, if in doubt, resolve in favor of disclosure.

  1. Disclosure for each Proposal Submission: At the time of submission of a new proposal, an Investigator must have completed their online financial disclosure in the I nfoEd External Interests Module. The University will not submit a proposal until such disclosure has been submitted.
  2. Changes in SFI: An updated disclosure shall be completed and filed within thirty (30) days at any time when an Investigator acquires or discovers a new reportable SFI not disclosed in the last disclosure. For existing Investigators on a project, new or newly identified SFIs will be reviewed promptly to determine if an FCOI exists, create a management plan if necessary and report the newly identified FCOI to the sponsor within 60 days if required.
  3. Human Subject Research: When research involves human subjects, the Investigator must disclose SFIs to the Institutional Review Board (IRB) with every submission of protocols. If an Investigator has an FCOI, but a management plan is not on file, the IRB will contact the VPR or their designee and hold approval of the protocol until the FCOIR makes a determination.
  4. New Investigators: If research is ongoing and an Investigator newly participating in the project discloses an SFI related to that research, those SFIs will be reviewed promptly to determine if an FCOI exists, create a management plan if necessary and report the newly identified FCOI to the sponsor within 60 days if required.

IV. Determination, Resolution, and Management of a Conflict of Interest

  1. The VPR will review SFI Disclosure Forms and, if an SFI is disclosed, the Investigator will be required to complete a Supplemental Information Request to Significant Financial Interest Disclosure. The VPR or his/her delegate performs an initial administrative review and refers all disclosed SFIs to the Financial Conflict of Interest in Research Committee.
  2. The Financial Conflict of Interest in Research Committee (FCOIR) is appointed by the VPR and serves as the resource with respect to the determination of relatedness of SFIs and the identification and management of COIs. The FCOIRC shall include an appointed chair and (5) additional appointed members with broad representation across the University, and may include one community member who is not a University employee.
  3. The FCOIRC, with the help of the Investigator and/or his/her department head and based on guidelines consistent with all applicable regulations, will determine if the SFI is related to a sponsored research project and, if so related, whether the SFI constitutes a financial conflict of interest (FCOI).
  4. If the FCOIRC identifies an FCOI, it will resolve the conflict by elimination, mitigation, or the creation of a management plan. The Investigator has to agree in writing to the conditions listed in such management plan. The following are examples of conditions that may be imposed:

Public disclosure of SFIs, including disclosure on manuscripts submitted for publication, on abstracts and posters submitted for presentation, and on informed consent documents;

    1. Monitoring of the research by independent reviewers;
    2. Modification of the research;
    3. Disqualification from participation in all or a portion of the activities that could be affected by the FCOI;
    4. Divestiture or reduction of the SFI;
    5. Severance of relationships that create actual or potential conflicts.
  1. An FCOI must be eliminated or a management plan agreed to before a related award will be set up. Neither the institution nor an Investigator may expend funds unless it has been determined that no FCOI exists or that the FCOI is manageable in accordance with the terms of a management plan.

V. Notification/Reporting

If an FCOI is identified, the FCOIRC is responsible for:

  1. Notification of the Investigator of the management plan designed by the Committee for his/her FCOI;
  2. Notification of the Office for Sponsored Programs (OSP) to assure that no spending of funds from related grants occurs without prior approval of the FCOIRC.
  3. Notification of the Office of Research Compliance of FCOI management plan when the research involves human subjects.
  4. Notification of research sponsors, as required, of any FCOIs, including any measures taken to reduce, manage, or eliminate such conflicts. The elements of such a report shall include, at least, the items enumerated under the FCOI Regulations.

The VPR or his/her delegate will notify the above individuals, offices, and sponsors on behalf of the FCOIRC. Reasonable efforts will be made to maintain the privacy of information gathered in the FCOIRC’s deliberations, within the limits imposed by applicable laws and regulations.

VI. Maintenance of Records

All records related to the implementation of this policy (e.g., Individual Financial Disclosure Forms, Supplemental Information Forms, minutes of the meetings of the COI in Research Management Committee, notifications to funding agencies, actions taken to resolve or mitigate FCOIs, etc.) will be maintained securely by the VPR for a period of at least three (3) years beyond the termination or completion of the sponsored award to which they relate, or until the resolution of any action involving those records, whichever is longer.  FCOI records shall be subject to periodic review for compliance  with this policy by the VPR or by any agency per applicable regulations.

VII. Subrecipients

If a subrecipient carries out a portion of the work, University shall take reasonable steps to ensure that any subrecipient and subrecipient Investigator complies with the applicable FCOI regulation.

University will establish, via a written agreement, the governing FCOI policy.

  1. Sub-recipient will certify that its FCOI policy complies with the respective regulations and, further, sub-recipient will report identified FCOIs for its investigators in a time frame that allows University to report identified FCOIs to the awarding agency.
  2. Alternatively, if a sub-recipient lacks a compliant FCOI policy, the subrecipient will be governed by the University’s FCOI policy; University will solicit and review sub-recipient Investigator disclosures and identify, manage and report FCOIs to the sponsor.

In the event that a sub-recipient notifies University of an FCOI for sub-recipient Investigators for which University is the prime awardee, University will promptly notify the sponsor.

VIII. Public Accessibility

Prior to expending any funds under a PHS-funded grant, cooperative agreement or contract, the VPR shall ensure public accessibility of information about the FCOI, via a written response to any   requestor within five (5) business days of a request, of information concerning an SFI which was disclosed and is still held by the senior/key personnel on the project, which is determined to be  related to the PHS-funded research, and which is determined to be a FCOI. The information shall consist of the information required to be provided under the FCOI Regulations.

IX. Monitoring Compliance/Mitigation

  1. The VPR will monitor for compliance with the policy.
  2. If the VPR learns of an SFI that was not timely disclosed or was not timely reviewed, the VPR, or his/her delegate, shall, in consultation with the FCOIRC and no later than the sixtieth (60th) day after learning of the SFI:
    1. determine whether the SFI is an FCOI; and
    2. if an FCOI exists, implement an interim management plan or implement other interim measures to ensure the objectivity of the research going forward.
  1. If an FCOI was not timely identified or managed or if an Investigator fails to comply with a management plan, the VPR shall no later than the 120th day after determining noncompliance:
    1. complete and document a retrospective review and determination as to whether research conducted during the period of noncompliance was biased in the design, conduct, or reporting of the research; and
    2. implement any measures necessary with regard to Investigator’s participation in the research between the date that the noncompliance is identified and the date the retrospective review is completed.
  1. For PHS and DOE-covered research projects, the retrospective review shall cover key elements as specified by federal regulations and may result in updating the Financial Conflict of Interest Report, notifying the PHS or DOE awarding component, and submitting a mitigation report as required by federal regulation.
  2. University will notify the PHS and DOE of instances in which the failure of an Investigator to comply with this policy or a management plan appears to have biased the design, conduct, or reporting (and purpose for DOE funded research) of funded research. The University will make information available to HHS, PHS and DOE awarding component as required by federal regulation.

X. Appeals

  1. In situations where an Investigator disputes the decision of the FCOIRC, the Investigator may request to present the case to the FCOIRC in person. An Investigator  who  disagrees  with  the FCOIRC’s determination may appeal in writing to the VPR. An appeal may be made in regard to  whether the professional judgment of the Investigator is likely to affect his or her conduct of research, but Investigators may not contest the terms and conditions of this.
  2. The VPR may agree with the FCOIRC’s findings and/or recommendations, or may amend such findings and/or recommendations. The VPR shall promptly notify the Investigator and the FCOIRC in writing of the conclusions of his/her review, including the actions that must be taken by the Investigator to comply with this policy.
  3. Upon receipt of the VPR’s written report, the Investigator must promptly comply with the actions specified in that report.

XI. Implementation and Enforcement

The Provost is the senior administrator responsible for overseeing the implementation of this Policy. The Provost has delegated the disclosure/review/management process to the Vice President for Research or his/her designee (VPR). The VPR, in consultation with the Dean of the appropriate School and the Investigator(s) Department Head, will review all breaches of the policy, including:

  1. failure to comply with the process (by refusal to respond, by responding with incomplete or knowingly inaccurate information, or otherwise);
  2. failure to remedy conflicts; and
  3. failure to comply with a prescribed management plan

Sanctions and penalties for those who knowingly and willfully disregard this policy, or refuse to   comply with its terms, will be determined by the VPR, in consultation with the Dean of the appropriate School, with advice from the Investigator(s) Department Head and the Department  of Faculty and  Staff Labor Relations . Sanctions include, but are not restricted to:

  • Letter of reprimand
  • Notification to professional and/or scientific societies, funding agencies and/or professional journals
  • Reassignment of duties Termination of grant support
  • Adjustment of research space allocation Adjustment of salary
  • Suspension
  • Dismissal

XII. Audit Procedures

In order to ensure that all declarations are being made and financial conflicts managed, the University will implement a relevant audit program through the University’s Office of Audit and Management Advisory Services.

REFERENCES

[1] E.g. American Heart Association and American Cancer Society

[2] For purposes of this definition, remuneration includes salary and any payment for services not

otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value

POLICY HISTORY

Policy created: 01/23/2015

Revisions:          01/30/2023 (Approved by Senior Policy Council and the President)

                               

Faculty Compensation, Policy on

Posted on by
Title: Faculty Compensation, Policy On
Policy Owner: Office of the Provost and Human Resources
Applies to: All Faculty excluding UConn Health
Campus Applicability: All campuses except UConn Health
Effective Date: November 11, 2022
For More Information, Contact Office of the Provost: provost@uconn.edu

Human Resources: hr@uconn.edu
Contact Information: (860) 486-3034
Official Website: http://www.hr.uconn.edu/

PURPOSE

To establish the standards under which regular payroll faculty may receive compensation from the University or external entities. As defined in this policy, such compensation must be in conformance with relevant state and federal regulations, including 2 CFR Part 200 (commonly referred to as Uniform Guidance) and the Connecticut Guide to the State Code of Ethics. This policy also defines the administration of faculty appointment terms.
This policy does not define rates of pay for activities or other contractual terms outlined in the collective bargaining agreement between the University of Connecticut and American Association of University Professors.

APPLIES TO 

All Faculty excluding UConn Health. Faculty refers to all regular payroll faculty: tenured and tenure-track, clinical, in-residence, research, extension, visiting, and lecturers. This policy does not apply to coaches/trainers, adjuncts, or academic staff: research assistants/associates, academic assistants, or scientist/scholars.

POLICY STATEMENT

Compensation for all applicable audiences must fall under regular compensation, summer salary, overload pay, consulting, or prizes and awards. All applicable employees and employees responsible for appointing or administering compensation for applicable employees must consider the full compensation landscape at UConn and comply with this policy and its accompanying Faculty Compensation Procedures.

I.         Regular Compensation

Appointment Term and Work Period. All faculty are appointed to either an academic year or annual year position. An academic year position has a nine- or ten-month assignment, in which the regular duties and responsibilities of the role fall primarily during the academic year[i]. The work period for an academic year position is defined in the Procedures. An annual year position has an eleven-month assignment, in which the regular duties and responsibilities of the role require effort consistently throughout the full year. The work period is all year round. Under the University’s faculty pay model, faculty are paid for 9-, 10-, and 11-month appointments over 12 months. Both academic year and annual year positions are paid over twelve months.

Salary. Full-time annual salary represents full renumeration for the duties and responsibilities associated with a faculty member’s regular workload and respective appointment term. Faculty may not receive additional compensation from university or external sources during the regular work period[ii] unless explicitly approved according to the summer salary, overload, consulting, or prizes/awards sections of this policy.

  1. Annual salary: Annual salary is the total compensation over the course of the year for the regular faculty appointment. Faculty have one or more pay components which comprise their annual salary:
    1. Base salary: Base salary is the base component of a faculty member’s annual salary, reflecting the pay tied only to the base term and    respective workload. All faculty have a base term and base component of their annual salary.
    2.  Additional Months: Faculty may have one or two additional months of effort/pay depending on the scope and complexity of a faculty administrator assignment. The rate of pay for this component is tied to the base salary rate.
    3.  Administrative Supplement: Faculty may earn a supplement for administrative work that is above their base pay or additional months. The rate of pay is not tied to the base salary rate.

b. Institutional Base Salary (IBS) is a term used specifically for sponsored projects and stems from the Office of Management and Budget’s  Uniform Guidance. IBS is the annual compensation paid for an individual’s regular appointment term and corresponding workload. At UConn, this is the equivalent of “annual salary” as defined above. IBS is inclusive of all regular pay components. A faculty member’s IBS is compensation for time spent on research, teaching, administration, or service. Institutional base salary does not include one-time payments, summer salary, or consulting.

        Workload. Every faculty member has a defined workload. The scope of work for a base faculty appointment typically includes some combination of teaching, research, and service, as defined in the appointment letter or the department’s governance documents. Any change to a faculty member’s defined workload such as a course reduction or administrative assignment must be approved by appropriate parties based on school/college policy and clearly documented with the dean’s office.

        Administrative Assignment. Faculty may be appointed to an administrative assignment with pay when the duties and responsibilities clearly exceed an individual’s base faculty appointment, and the required effort takes place over the course of the year. Administrative assignments may include a temporary redefinition of the individual’s appointment term, annual salary, or workload for the length of the appointment. Administrative assignments must be approved in writing by the Dean and any other supervisors in advance of an offer. Appointments must include an appointment letter describing the terms of the appointment and must be processed through regular payroll. The new full-time annual salary associated with an administrative assignment represents full renumeration for the new workload and may consist of multiple pay components. The University applies salary increases proportionately to each pay component, with the exception of promotional increases which apply only to the base salary component. Administrative appointments are at-will and subject to non-renewal or termination at the discretion of the supervisor. Should a faculty member no longer continue in an administrative appointment, the faculty member will return to the base faculty appointment term and base faculty rate in effect at that time.

        Compensation above the institutional base salary is not permitted on activities funded by federal grants or contracts.

        Research/Professional and Sabbatical Leaves. Research/professional leaves and sabbatical leaves are considered active service to the University and a redefinition of the faculty member’s regular workload for the leave period. Sabbatical pay is based on the faculty base appointment. Please refer to the provost’s guidelines for the administration of faculty leaves of absence.

        II.       Summer Salary

        Faculty may be assigned teaching, research, service, or administrative duties during the period in which they are not already scheduled to work according to their regular academic year or annual year appointment. The table below describes the maximum effort and compensation a faculty member may earn as summer salary according to regular appointment term. Time and pay for faculty working on externally funded sponsored projects or the equivalent effort on university funds cannot exceed the daily rate of pay for daily effort (i.e., max pay cannot be condensed and paid out over a shorter period).

        Appointment Term Effort Proportion of Current Full-Time Annual Salary Time Period[iii]
        Nine-month Three months 3/9 May 23 – August 22
        Ten-month Two months 2/10 June 23 – August 22
        Eleven-month One month 1/11 Eligible to be paid out at any point in the year

        Eleven-month faculty appointments are unique in that faculty are scheduled to work all year round, with one additional month of non-work time spread out over the course of the year. Given there is no pre-determined period in which this additional month takes place, faculty may earn their additional month of compensation at any point in the year, subject to all other requirements of this policy.

        It is the responsibility of the faculty performing research activities for grants or contracts to adhere to the policies of the applicable funding agency during this period. Many federal agencies have additional compensation stipulations. For instance, at the time of this writing, NSF has proposal limits on summer earnings to the equivalent of two months of salary, and HHS “restricts the amount of direct salary of an individual under an NIH grant or cooperative agreement or applicable contract to Executive Level II of the Federal Executive Pay scale.”

        Summer salary compensation may be waived if the faculty member chooses to accept payment in the form of faculty research funds. Such requests must be clearly documented, in advance of performing services, in line with the Procedures. Waived compensation in the form of faculty research funds is not considered personal compensation and cannot be used to supplement a faculty member’s full-time annual salary or summer salary in future years. Waived compensation is not included in the determination of the aforementioned maximum compensation.

        III.     Overload Pay

        On occasion, faculty may be asked to perform work for the University that is substantially different from or in addition to the essential duties and responsibilities defined in the faculty member’s regular appointment. Such work must contribute to the mission and necessary business of the University. Faculty being considered for overload activities must demonstrate a unique qualification to perform the work. Overload pay may be appropriate for activities including, but not limited to, teaching during winter or May intercession, online course development sponsored by CETL, outreach, performance, or academic/student support. All requests for overload pay must be approved by the department head, dean, provost, and human resources as needed via the University’s formal approval process[iv] in advance of the start of the activity. Total overload pay should not exceed 25% of the twelve-month equivalent of annual salary each year. Any exception to the 25% cap will be rare and requires department head, dean, provost, and president approval. Overload assignments will only be considered if they meet the following criteria:

        1. The activity must not interfere with the faculty member’s ability to carry out the duties and responsibilities associated with their regular faculty appointment. The individual must be satisfactorily performing regularly assigned duties.
        2. The activity must clearly fall outside of full-time (100%) effort in the regular appointment and should not be used as a regular supplement to an individual’s salary.

        Overload compensation may be waived if the faculty member chooses to accept payment in the form of faculty research funds. Such requests must be clearly documented, in advance of performing services, in line with the Procedures. Waived compensation in the form of faculty research funds is not considered personal compensation and cannot be used to supplement a faculty member’s full-time annual salary or summer salary in future years.

        IV.    Consulting

        Consulting is an activity performed by a faculty member for compensation because of their expertise in their field (while not acting as a university employee), across any period of the year. Consulting encompasses work including, but not limited to; receiving honoraria for talks, consulting on research with other entities, clinical work with other entities (even when required to continue licensure needed for the faculty member’s appointment), teaching at other institutions, consulting with private industry, and compensated or uncompensated work with faculty-affiliated companies. Consulting is governed by the “Policy on Consulting for Faculty and Members of the Faculty Bargaining Unit” and associated Procedures. It is the responsibility of the faculty member to adhere to all policies and to follow all procedures related to faculty consulting. These can be found at policy.uconn.edu.

        Royalties received by a faculty member do not fall under the purview of the consulting policy or any other aspect of this compensation policy.

        V.      Prizes and Awards

        Compensation in recognition of internal or external awards is allowable according to the criteria defined below and does not contribute towards total eligible earnings for regular, summer, and overload pay.

        Internal Awards. The University may award faculty in recognition of exceptional teaching, research, or service to the University. Awards should represent significant accomplishment and can in no way reflect payment for services. Whenever appropriate and possible, award programs should reward faculty with faculty research funds (waived compensation) rather than personal compensation. Whether waived compensation or personal compensation, the payment type must be determined and communicated clearly when establishing award criteria and cannot be changed once an award has been granted. An individual faculty member may not normally accept more than $10,000 in personal compensation awards each year. Criteria for awards should be established and communicated in advance of the selection process; the selection of awardees should be conducted by a committee with expertise in the relevant area. Newly established award programs must be approved in writing by the dean and provost in advance. Once an award program has been established, individual award payments in the form of personal compensation must be approved in writing by the dean prior to payment. Internal awards are not considered part of a faculty member’s full-time annual or institutional base salary. Internal awards cannot be charged to grants.

        External Prizes and Awards. The University acknowledges that faculty may be the recipient of national and international awards of excellence which may include a monetary award. Such external awards bring recognition to the recipient and to the University. Awards should represent significant accomplishment and can in no way reflect payment for services. Faculty must notify the provost upon notice of award recognition, prior to accepting any compensation, to evaluate whether a monetary award qualifies for this status.[v]  External awards are not considered part of a faculty member’s full-time annual or institutional base salary.

        ENFORCEMENT

        Violations of this policy or associated procedures 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, or other applicable University Policies.

        PROCEDURES/FORMS

        Procedures for the Faculty Compensation Policy and other resources are available here.

        Guide to the State Code of Ethics

        [i] Dates defined in Faculty Compensation Procedures/Pay Model

        [ii] Defined in Faculty Compensation Procedures/Pay Model

        [iii] Dates may vary in leap years. Office of Payroll determines exact dates of work period according to Faculty Pay Model.

        [iv] Defined in Faculty Compensation Procedures

        [v] Provost will consult with appropriate offices, including Office of University Compliance and Tax and Compliance. Protocols defined in Faculty Compensation Procedures

        POLICY HISTORY

        Policy Created:  April 11, 2006 [Extra Compensation Policy Approved by the Board of Trustees]

        Revisions: June 13, 2022 [Approved by the President; Effective date November 10, 2022]; June 10, 2015 [Approved by Board of Trustees]; September 26, 2006 [Approved by Board of Trustees];

         

        Employment and Contracting for Service of Relatives, Policy on

        Posted on by
        Title: Employment and Contracting for Service of Relatives, Policy on
        Policy Owner: Office of University Compliance and 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 Human Resources, Labor Relations
        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 https://hr.uconn.edu/employee-relations/

        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.

        POLICY HISTORY

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

        Electronic (E-mail) Communication Policy

        Posted on by
        Title: Electronic (E-mail) Communication Policy
        Policy Owner: Information Technology Services
        Applies to: Faculty, Staff, Affiliates and Student Employees
        Campus Applicability: Storrs and Regionals, except UConn Health
        Approval Date: August 30, 2023
        Effective Date: October 1, 2023
        For More Information, Contact: UConn Information Technology Services
        Contact Information: techsupport@uconn.edu
        Official Website: https://its.uconn.edu

        DEFINITIONS

        University Provided Email Services – University-provided email services refers to the email accounts and related services that educational institutions offer to their students, faculty, and staff. These email services can be hosted on the University’s servers or in the cloud and come with an email address in the form of username@uconn.edu

        PURPOSE

        This policy applies to all uses and users of University provided email services, including faculty, staff, volunteers, contractors and affiliates. The purpose of this policy is to describe the permitted and appropriate use of University provided email to ensure compliance with relevant laws, regulations and policies, including those concerning the retention and protection of emails and attendant data.

        POLICY STATEMENT

        The University provides email services to support activities associated with academic, administrative, research and philanthropic functions in support of its overall mission. The University recognizes and has established email as an official means of communication. All faculty and staff are provided a UCONN.EDU email account which is the official address to which the University will send email communications. All communications related to University functions shall use the University provided email services to ensure compliance with University policies and regulatory compliance.

        Individual Users are expected to read in a timely manner all official University email messages sent to their University email address.

        University email services are provided solely for the purpose of conducting University business and are subject to all applicable University policies including the Code of Conduct as well as state and  federal laws.  Occasional use of email services for personal, non-University related purposes is allowed but subject to the Code of Conduct.

        University email accounts and information sent via University email services are the property of the University.  As a public institution, with limited exceptions, virtually all University records, including email communications, are subject to laws governing public records.  Because University email accounts are University property, the University has the right to access such accounts for legitimate business purposes as may be required and/or authorized by appropriate parties.  This includes but is not limited to access necessary to respond to requests made pursuant to the Connecticut Freedom of Information Act (FOIA), the Family Educational Rights and Privacy Act (FERPA),and/or subpoenas. Individuals are prohibited from directly accessing the email accounts of others unless they are authorized to do so for University business purposes.

        Users of University email services are responsible for safeguarding the privacy and security of information sent electronically in accordance with applicable laws and policies. Automated copying or forwarding of email from University accounts to non-University accounts is prohibited. Any user who moves a copy of email sent to a University email account to a non-University email account expressly assumes personal responsibility for the security and privacy of that email and any information contained therein.  Moving a University email into a non-University account may subject the non-University account to review in response to a subpoena, FOIA request or other legal process.

        RELATED UNIVERSITY POLICIES

        Code of Conduct

        Electronic Privacy and Disclaimer Notice

        FERPA Policy

        General Rules of Conduct

        Records Management Policy

        University Guide to the State Code of Ethics

        POLICY HISTORY

        Policy adopted: November 14, 2003

        Revisions:
        June 1, 2005
        June 19, 2007
        March 13, 2015
        August 30, 2023 (Approved by the Senior Policy Council and the President)

        Faculty and Staff Handbook

        Posted on by
        Title: Faculty and Staff Handbook
        Policy Owner: Office of the Provost
        Applies to: Faculty and Staff
        Campus Applicability:  Resource for All Campuses
        Effective Date: July 1, 2011
        For More Information, Contact Office of the Provost
        Contact Information: (860) 486-4037
        Official Website: http://guide.uconn.edu/

         

        As of July 1, 2011, the Faculty & Staff Resource Guide is the Official Faculty and Staff Handbook of the University of Connecticut.

        Please consult the Guide for any of your academic, employee, or university needs. Please contact guide@uconn.edu to suggest adding, altering, or archiving material found in the Guide.

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

        Posted on by
        Title: Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on
        Policy Owner: Office of the Provost
        Applies to: Faculty and members of the faculty bargaining units; Management-exempt personnel with faculty appointments
        Campus Applicability: All Campuses
        Effective Date: June 29, 2022
        For More Information, Contact: Faculty Consulting Office
        Contact Information: Storrs and Regional Campuses: Sarah Croucher, sarah.croucher@uconn.edu

        UConn Health: Carla Rash, rash@uchc.edu
        Official Website: http://consulting.uconn.edu/

         

        1. BACKGROUND

        The University recognizes the benefits derived from faculty members participating in consulting activities with outside entities. Such activities are vital for professional service, provide intellectual enrichment of faculty members and students, may foster economic development, and enhance the reputation of the University. Participation in such activities is a norm for faculty at all highly ranked U.S. public research universities. All activities where outside compensation is received that are related to the expertise of a faculty member fall within the purview of this policy, as are any activities with faculty affiliated companies.

        2. PURPOSE

        This policy provides a framework for consulting work with external entities to ensure compliance with the State of Connecticut Code of Ethics (Conn. General Stat §1-84(r)), other applicable policies, and to ensure such work does not conflict with University employment.

        3. SCOPE

        This policy applies to all faculty at the University of Connecticut and the University of Connecticut Health Center, and all staff eligible to be members of the faculty bargaining units (hereafter described as “faculty members”). The policy applies to management-exempt employees only when they have a base faculty appointment, as determined by their appointment letter. Faculty members who are employed by the University below 0.5 FTE (full-time equivalent) do not need approval to engage in consulting activities. However, such faculty may voluntarily elect to request prior approval for consulting activities. Once a faculty member in this position has requested approval to consult, all subsequent consulting activities in that reporting year must also obtain such approval.

        4. DEFINITIONS

        1.  Consulting: an activity (e.g., provide services, give advice or analysis) undertaken by a faculty member for compensation as a result of their expertise or prominence in their field, while not acting in their official capacity as a State employee (i.e., in their own time). Activities such as serving on grant review panels, giving talks, or reviewing academic works are classified as consulting when undertaken for compensation. Paid or unpaid work conducted for a faculty affiliated company is also considered consulting.
        2.  Compensation: any form of payment received for the consulting activity. Compensation for consulting activities includes, but is not limited to; honoraria, stipends, payments in goods or services, stocks or stock options, other interests of value, or any forms of compensation (including “luxury travel”) above necessary expenses, even if this is intended to support costs associated with undertaking the activity.
        3.  Contracting entity: the business, nonprofit organization, government body, individual, or other organization that engages and compensates the faculty member for the consulting activity.
        4.  Faculty affiliated company (FAC): A faculty affiliated company (or other legal entity) is a for-profit or not-for-profit business where a faculty member or member of their immediate family: 1) is a director, officer, owner, or limited or general partner or, 2) is a beneficiary of a trust, or holder of stock constituting five percent or more of the total outstanding stock of any class.
        5.  Time due to the University: any time necessary for successfully carrying out the workload duties assigned to a faculty member. The University’s Bylaws and policies prohibit faculty from consulting on “time due to the university.”
        6.  Normal work time: the usual time during which a faculty member is expected to perform their job duties. These times and job duties may be defined in specific appointment letters, workload policies, or other workload assignment documentation.
        7.  Reconciliation: the process of closing out each approved consulting request after the activity has taken place (or was due to take place if it does not occur) by confirming or updating information regarding the time spent consulting and the compensation received.

        5. POLICY

        All full-time faculty members must receive written permission from the appropriate supervisory hierarchy prior to engaging in any consulting activity. All consulting requests and reconciliations must be submitted via the University online consulting request system. Faculty must adhere to the University’s procedures associated with this policy.

        Consulting approval is not required for compensation received from royalties.

        The provost will submit an annual report of consulting activities for all faculty members to the Joint Audit and Compliance Committee of the Board of Trustees. 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.

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

        6. ENFORCEMENT

        Violations of this policy may result in appropriate disciplinary measures in accordance with University Bylaws, General Rules of Conduct for all University Employees, and applicable collective bargaining agreements.

        Faculty members who do not receive prior approval under this policy are 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, as outlined in the associated Procedures.

        7. PROCEDURES 

        Procedures on Consulting for Faculty and Members of the Faculty Bargaining Unit are linked here.

        POLICY HISTORY

        *Policy Created: September 25, 2007

        *Revisions: 06/29/2022, 06/29/2019, 03/25/2015, 04/24/2013, 11/12/2012, 04/13/2011, 04/20/2010

        *Approved by the Board of Trustees.

        Compliance Training Policy

        Posted on by
        Title: Compliance Training Policy
        Policy Owner: Office of University Compliance
        Applies to: Workforce Members
        Campus Applicability: All University campuses, including UConn Health
        Approval Date: June 27, 2024
        Effective Date: June 27, 2024
        For More Information, Contact Office of University Compliance
        Contact Information: (860) 486-2530
        Official Website: https://compliance.uconn.edu/

        PURPOSE

        Training is an essential part of an effective compliance and ethics program. As recipients of federal funding, the University is required to provide all Workforce Members, including graduate assistants 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 all applicable University policies, and federal and state laws and regulations. Compliance training is intended to benefit the University community by helping to ensure that its members understand their responsibilities and by fostering a culture of compliance and ethical behavior.

        DEFINITIONS

        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

        Training Requirements
        All University Workforce Members are required to complete compliance training. Specific training requirements may differ in content, delivery, or frequency based on a Workforce Member’s role and responsibilities at the University in conjunction with other University policies, laws, and regulations.

        Additional or Specialized Training
        Workforce Members may be required to participate in additional and/or specialized compliance-related training to maintain the University’s compliance with applicable University policies, and federal and state laws and regulations. Training may be provided by the Office of University Compliance or another University department or entity with compliance-related responsibilities.

        Attestation
        Upon completion of any required compliance training, Workforce Members may be required to attest that they completed the training, understand the content and resources provided,  as well as the potential disciplinary actions or sanctions that may result from any incidents of non-compliance with University policies and applicable laws and regulations.

        ENFORCEMENT

        Failure to complete assigned compliance trainings by the established deadline 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/or the University of Connecticut Student Code. 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.

        POLICY HISTORY

        Policy created: 08/13/2008 Approved by Executive Compliance Committee

        Revisions:  06/27/2024 Approved by the Senior Policy Council and the President; 06/11/2020 Approved by University Compliance Committee and UConn Health’s Administrative Policy Committee on 06/25/2020.