Students

UConn Web Policy

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

 

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

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

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

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

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

Definitions:

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

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

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

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

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

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

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

Electronic Privacy and Disclaimer Notice

Web Site Accessibility

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

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

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

Responsibilities:

The Chief Information Officer has overall responsibility for this policy.

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

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

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

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

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

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

Enforcement and Review:

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

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

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

Special Payroll Policy

Title: Special Payroll Policy
Policy Owner: Board of Trustees
Applies to: Faculty, Staff, Students
Campus Applicability:  Storrs and Regional Campuses
Effective Date: December 7, 2007
For More Information, Contact Human Resources
Contact Information: (860) 486-3034
Official Website: http://www.hr.uconn.edu/

Background and reasons for the policy:  The University of Connecticut requires the use of project based, seasonal, durational as well as temporary professional personnel to meet University staffing needs such as instructional and research support, athletic and theatrical program activities, limited assignment managerial support as well as support for grant and research projects and community organizations engaged in activities with the University.

Purpose: To clarify the statutory framework within which the University hires such staff and to provide appropriate guidelines for the use of such services.

Expected Institutional Outcome: This policy will support statutorily compliant access to instiutionally necessary staffing resources and expedite staffing of project based, seasonal, durational and temporary professional assignments.

Applicability of Policy: This policy applies to the hiring of project based, seasonal, durational and temporary professional personnel services at the Storrs and regional campuses.  Positions appropriate to established collective bargaining units are not to be placed on the Special Payroll.

Policy Statement: Pursuant to CGS 10a-20 and 10a-108, authorized hiring officers may appoint temporary, short term, project based, seasonal, durational and professional staff to meet staffing needs associated with university programs and activities.  Appointees to the Special Payroll do not receive benefits, although professional employees hired pursuant to CGS 10a-20 may purchase medical coverage at group rates under CGS 5-259c.  Positions appropriate to established collective bargaining units are not to be placed on the Special Payroll.

 

Approved by the Board of Trustees: December 7, 2007

Outdoor Amplified and Projected Sound Policy

Title: Outdoor Amplified and Projected Sound Policy
Policy Owner: Office of the Provost and Office of the Vice President for Student Life and Enrollment
Applies to: Workforce Members, Students, Others
Campus Applicability: Storrs and Regional Campuses
Approval Date: August 20, 2024
Effective Date: August 21, 2024
For More Information, Contact Office of the Provost or Office of the Vice President for Student Life and Enrollment
Contact Information: provost@uconn.edu or VPSLE@uconn.edu
Official Website: https://provost.uconn.edu or https://studentlife.uconn.edu

PURPOSE

To manage and regulate the use of outdoor Amplified and Projected Sound on University Property to ensure a conducive academic environment.

APPLIES TO

Storrs and Regional campuses, including all students, Workforce Members and visitors.  This policy does not apply to the School of Law.

EXCLUSIONS

This policy does not apply to the use of Amplified and Projected Sound for the following:

University Athletics and Athletic Events: All University Athletics organized/sponsored events and activities, including practices, games, and other athletic activities.

The following University Events: Events and activities sponsored by the Offices of the President, Provost, or Vice President for Student Life and Enrollment, and University-wide Admissions events (i.e., UConn Bound Day, Fall Campus Visit Days, etc.), Student Activities sponsored University-wide events (i.e., WOW, Homecoming, Family Weekend, Winter Weekend, Spring Weekend, etc.) and Student Activities sponsored Outdoor Movies, Convocation, and Commencement activities and events.

The University Marching Band and Athletic Bands: official, organized practices and performances as directed by the band director or their designee.

DEFINITIONS

Amplified and Projected Sound: This refers to any sound that is electronically amplified or projected through the use of equipment such as amplifiers, speakers, DJs, megaphones, or other sound systems. It also includes the use of acoustic instruments like trumpets, trombones, violins, air horns, drums and other similar instruments or items that can produce significant sound levels.

Scheduling Office: A space management office responsible for managing and approving requests for the use of University spaces. The Scheduling Office communicates compliance information, including space-related and activity-related rules, regulations, and requirements, covering local, state, and federal laws, as well as internal policies. This may involve coordination with other University offices, including but not limited to Environmental Health and Safety Services, Facilities Operations (i.e., Landscape and Grounds, electrical services, custodial services, Central Warehouse, etc.), Housing and Residential Life, Parking and Transportation, University Safety (i.e., the Fire Marshal’s Office and the Fire Department, the UConn Police Department, etc.), as well as external entities such as Call Before You Dig (CBYD).

University Property: Any building, space or area under the control of the University of Connecticut at the Storrs & Regional Campuses.

Venue: Any location where an event takes place.

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

1. Outdoor Amplified and Projected Sound Conditions

Amplified and Projected Sound is permitted on campus within specified times and locations to minimize disruption to academic activities, residence halls, and public spaces. The following conditions govern the use of Amplified and Projected Sound.

Subject to the Additional Conditions, Special Permissions and Restrictions below, Amplified and Projected Sound is permitted as follows:

  • Weekdays (Monday through Friday): Amplified and Projected Sound may be permitted between 5 p.m. and 10 p.m.
  • Weekends (Saturdays and Sundays): Amplified and Projected Sound may be permitted between 9 a.m. and 10 p.m. on Saturdays and Sundays.
  • Quiet Hours during Finals: The University observes a traditional period of quiet hours in recognition of the study period in advance of final exams and the exams themselves. This is in effect 24 hours per day each semester, beginning at 11:59 p.m. on the last day of classes through 11:59 p.m. on the last day of finals or Commencement.

2. Additional Conditions:

    • Academic Classes or University Business Disruptions: Amplified and Projected Sound must not be disruptive to or interfere with academic courses or University business.
    • Sound Levels: Sound levels that are disruptive to the education environment, such that they may interfere with classes or other University activity, are prohibited. For example, sound levels must not exceed 85 decibels (dB) at a distance of 50 feet from the source. Requests for sound levels exceeding this limit require additional permissions and must be submitted to the Scheduling Office. Failure to comply with requests to reduce volume that is in excess of the approved limit may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code of Conduct, including the immediate cancellation of the remainder of an ongoing event or gathering.
    • Outdoor Spaces adjacent to Residence Halls:
    • Sunday through Thursday: Amplified and Projected Sound is not permitted.
    • Fridays: Amplified and Projected Sound is permitted from 5 p.m. to 9 p.m.
    • Saturdays: Amplified and Projected Sound is permitted from 9 a.m. to 9 p.m.

3. Special Permissions

    • Event organizers may seek additional permissions for Amplified and Projected Sound from the designated Scheduling Office.
    • Permissions may be granted based on the specific location and the nature of other activities occurring at the same time.

    4. Restrictions

    Permission may be denied by the Scheduling Office based on the impact of Amplified and Projected Sound on nearby activities and events.

    PROCEDURES

    A link containing information on the Scheduling Office will be listed at https://inform.uconn.edu.

    ENFORCEMENT

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

    The Provost or designee and the Vice President for Student Life and Enrollment or designee shall review this policy annually and will recommend revisions and/or updates as may be appropriate.

    Questions about this Policy may be directed to the Office of the Provost at provost@uconn.edu or the Office of the Vice President for Life and Enrollment at VPSLE@uconn.edu.

    POLICY HISTORY

    Policy created: 02/11/2002

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

    Restrictions of Publication Rights and Foreign Nationals in Sponsored Research Contracts

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

     

     

    INTRODUCTION

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

    KEY ELEMENTS OF THE POLICY

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

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

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

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

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

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

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

    People with Disabilities, Policy Statement:

    Title: People with Disabilities, Policy Statement:
    Policy Owner: Office of Institutional Equity
    Applies to: Faculty, Staff, Students, Others
    Campus Applicability:  All Campuses and Programs, except UConn Health
    Effective Date: November 15, 2011
    For More Information, Contact Office of Institutional Equity
    Contact Information: (860) 486-2943
    Official Website: http://www.equity.uconn.edu/

    The University of Connecticut is committed to achieving equal educational and employment opportunity and full participation for persons with disabilities.  It is the University’s policy that no qualified person be excluded from consideration for employment, participation in any University program or activity, be denied the benefits of any University program or activity, or otherwise be subjected to discrimination with regard to any University program or activity.  This policy derives from the University’s commitment to nondiscrimination for all persons in employment, academic programs, and access to facilities, programs, activities, and services.

    A person with a disability must be ensured the same access to programs, opportunities, and activities at the University as all others.  Existing barriers, whether physical, programmatic, or attitudinal must be removed.  Further, there must be ongoing vigilance to ensure that new barriers are not erected.

    The University’s efforts to accommodate people with disabilities must be measured against the goal of full participation and integration.  Services and programs to promote these benefits for people with disabilities shall complement and support, but not duplicate, the University’s regular services and programs.

    Achieving full participation and integration of people with disabilities requires the cooperative efforts of all of the University’s departments, offices, and personnel.  To this end, the University will continue to strive to achieve excellence in its services and to assure that its services are delivered equitably and efficiently to all of its members.

    Anyone with questions regarding this policy is encouraged to consult the Office of Institutional Equity (OIE).  The office is located in Wood Hall, Unit 4175, 241 Glenbrook Road, Storrs, Connecticut 06269-4175, telephone, 860-486-2943.

     

     

     

    Providing Information in Alternative Formats, Policy on

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

    PURPOSE

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

    DEFINITIONS

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

    POLICY STATEMENT

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

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

    ENFORCEMENT

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

    PROCEDURES/FORMS

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

    Student Requests:

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

    Contact:

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

    Workforce Requests:

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

    UConn ADA Compliance & Accommodations
    UConn Health ADA Compliance & Accommodations

    Contact UConn:

    ADA Accommodations Case Manager

    Allyn Larabee Brown Building

    9 Walters Ave Depot Campus – Unit 5075

    Storrs, CT 06269-5075

    Phone: (860) 486-2598

    Email: tiffanie.roback@uconn.edu

    Contact UConn Health:

    ADA Case Manager

    16 Munson Road, 5th Floor

    Farmington, CT 06032

    Phone: (860) 679-2426

    Email:  moreland@uchc.edu

     

    The University’s Interim ADA Coordinator is:

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

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

    POLICY HISTORY

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

                                   

    Non-Retaliation Policy

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

    PURPOSE

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

    POLICY STATEMENT

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

    DEFINITIONS

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

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

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

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

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

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

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

     

    REPORTING PROCESS

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

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

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

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

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

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

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

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

    Website: https://www.ceui.org/

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

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

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

    Website: https://cpfu.org/

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

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

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

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

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

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

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

     

    ADDITIONAL RESOURCES

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

    Employee Assistant Program

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

    University Ombuds

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

    Office of the Dean of Students

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

    UConn Cultural Centers

    Website: https://provost.uconn.edu/cultural-centers-programs/

    Office for Diversity and Inclusion:

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

     

    POLICY HISTORY

    Policy created:  09/22/2009

    Revisions:

    10/22/2012 (Non-substantive revisions)

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

    Mission And Purposes of The University of Connecticut

    Title: Mission And Purposes of The University of Connecticut
    Policy Owner: Board of Trustees
    Applies to: Faculty, Staff, Students
    Campus Applicability:
    Effective Date: June 20, 2006
    For More Information, Contact Board of Trustees Office
    Contact Information: (860) 486-2337
    Official Website: http://boardoftrustees.uconn.edu/

     

    (Adopted by the Board of Trustees on April 11, 2006 and amended on June 20, 2006)

    The University of Connecticut is dedicated to excellence demonstrated through national and international recognition.  As Connecticut’s public research university, through freedom of academic inquiry and expression, we create and disseminate knowledge by means of scholarly and creative achievements, graduate and professional education, and outreach. 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 research, teaching, service, and outreach, we embrace diversity and cultivate leadership, integrity, and engaged citizenship in our students, faculty, staff, and alumni.  As our state’s flagship public university, and as a 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.

    Human Subjects Research

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

    REASON FOR POLICY

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

    APPLIES TO

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

    DEFINITIONS

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

    Human Subject or Human Participant:

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

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

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

    Research:

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

    POLICY STATEMENT

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

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

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

    Designated IRBs are granted the authority to:

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

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

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

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

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

    ENFORCEMENT

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

    ADDITIONAL RESOURCES

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

    21 CFR part 50

    21 CFR part 56

    21 CFR part 312

    21 CFR part 314

    21 CFR part 812

    ICH GCP (E6)

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

    POLICY HISTORY

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

    Financial Conflicts of Interest in Research

    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)