While pursuing its academic mission to generate and apply knowledge through teaching, research, and public service, the University of Nevada, Las Vegas (UNLV) maintains a firm commitment to the principles of integrity and transparency. The University has developed internal policies and procedures consistent with state, federal, Nevada System of Higher Education (NSHE) regulations to ensure that employees do not engage in any activities that could place them in a conflict with their official responsibilities and any other interests or obligations.
Overview
The University of Nevada, Las Vegas recognizes that employee involvement in activities and cultivation of relationships outside the university enhances the institutional mission. External business and service contacts facilitate innovation, collaboration, and support. Accordingly, UNLV allows and encourages its faculty and staff to pursue external opportunities. All individuals are expected to act in the best interest of the University and the public it serves, and to uphold the highest standards of professional and fiscal conduct.
A conflict of interest is a situation in which an employee’s professional judgment and objectivity may be compromised or biased by financial or other personal considerations. A conflict of commitment or effort occurs when an employee’s participation in outside activities, whether paid or unpaid, involves a commitment of time that may interfere with his or her ability to meet institutional responsibilities. Since UNLV supports employee participation in outside activities and relationships that further the mission of the University, potential conflicts of interest and/or commitment are unavoidable. These external connections should not interfere with an individual’s official duties and obligations to the University. Faculty and staff should never use their official position or influence to acquire financial rewards or other gain for themselves, their relatives, friends, or personal associates, at the expense of the University.
Because outside interactions are accompanied by an increased potential for conflict of interest and/or commitment, the University has developed a robust set of policies and procedures consistent with applicable state and federal regulations for identifying, reducing, managing, and/or eliminating such conflicts.
2024 COI Information Forum
The webinar, held on Feb. 20, 2024, provided a general overview of the conflict of interest policies and procedures, as well as tips on how to successfully complete the required disclosure.
Policies and Guidelines
The institutional Conflict of Interest/Compensated Outside Services Policy is to ensure that the University is in compliance with federal requirements, Nevada Revised Statutes, and NSHE Code while maintaining the public’s confidence in the integrity of research and other activities of the institution. UNLV faculty, staff, and student employees are encouraged to participate in outside activities, provided they do not interfere with the fundamental obligation to act in the best interest of the university.
The COI/COS Policy enables university employees to recognize and disclose outside activities (compensated or not) that may create a conflict of interest. Potential conflicts must be properly reviewed and, if necessary, managed or eliminated without detriment to the reputation, credibility, or position of the institution and individual(s) concerned.
Internal Policies and Guidelines
- The Conflict of Interest/Compensated Outside Services Policy establishes requirements for identifying, managing, reducing, and/or eliminating conflicts of interest and managing compensated outside services.
- The Conflict of Interest Rules and Procedures provides procedural guidance related to the COI/COS Policy.
External Policies and Guidelines
- NSHE Board of Regents Handbook Title 4, Chapter 10, Section 1.7 specifies conflicts of interest that are prohibited for any employee of the Nevada System of Higher Education.
- NSHE Board of Regents Handbook Title 4 Chapter 3, Section 9 details limits on compensated outside services.
Disclosure Process
The University relies on a process of disclosure through self-reporting. The act of disclosure is not suggestive of any impropriety; on the contrary, it is a demonstration of transparency. Unless conflicts of interest and/or compensated outside services are disclosed in a timely and clear manner, they cannot be reviewed and managed as appropriate. The University is not primarily concerned about the amount of compensation received, but rather about time commitments and potential conflicts of financial interest, particularly significant ones.
The conflict of interest/commitment disclosure process at UNLV primarily involves two formal actions:
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Request by a faculty or staff member for approval of an outside activity using the Outside Activity Request Form
Some routine academic activities are considered pre-approved and do not require completion of the Request Form. The Outside Activity Request Form must be completed and forwarded to the supervisor for approval each time a new external activity that does not meet the requirements for pre-approval is undertaken. An outline of the outside activity request process is provided below.
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Completion of the Annual Conflict of Interest/Compensated Outside Services Disclosure Form by all employees
On an annual basis, and prior to submission for funding of any new project that may pose a conflict of interest, all employees must provide information on the nature and extent of their compensated outside services and potential conflicts of interest/financial interest for the preceding 12 months using the Annual Conflict of Interest/Compensated Outside Services Disclosure Form. All employees are required to complete the Disclosure Form whether or not they engaged in any outside activities. The form may be previewed at the link below. Aggregate institutional data on conflict of interest and compensated outside services are reported to the Nevada System of Higher Education annually.
At the time of the annual reporting period (typically in February), all employees who are required to provide a disclosure are sent a personalized link to the electronic Disclosure Form by email. Individuals needing to complete a Disclosure Form outside of the usual reporting period should send a request for a link to the electronic form to facultyaffairs@unlv.edu.
Supervisors/department chairs are responsible for ensuring that all Disclosure Forms are received by the due date, which is set annually by the Executive Vice President and Provost.
Preview of Annual Conflict of Interest/Compensated Outside Services Disclosure Form
Financial Conflicts of Interest (FCOI) with research funded by the Public Health Service
The Financial Conflict of Interest (FCOI) reporting process allows institutions to report the existence of any identified financial conflicts of interest to the Public Health Service as required by Federal regulation, specifically Title 42 Code of Federal Regulation Part 50 Subpart F for grants and cooperative agreements.
Institutional Conflicts of Interests
The University of Nevada, Las Vegas and its employees are bound by Nevada State Law regarding Ethics in Government (codified at NRS 281A). The University must avoid and/or manage conflicts of interests where its beneficial relationship with corporate entities may place it in conflict with its responsibilities as a public institution. Also, the University must abide by NSHE Code. See Higher Education and the Common Good (NSHE Code T2 Ch2, Section 2.1.1)
Matters that may involve institutional conflict of interests may be considered by the COI Designated Officer or the COI Committee or referred to University Counsel.
Working with Dynamic PDF Forms
The Outside Activity Request Form is an interactive PDF form and requires a digital signature. More information on working with dynamic PDF forms is available below.
Oversight Committee
UNLV’s Conflict of Interest Rules and Procedures authorize the Conflict of Interest Oversight Committee (COIOC) to implement two broad functions:
- To review significant financial interests disclosed by federally funded investigators, and,
- To serve as the “review committee” (NSHE Code Title 4 Chapter 3, Section 9.8) to hear appeals of supervisor denials of faculty requests to engage in compensated outside activities.
Current Committee Membership
- Brenda Buck, Department of Geoscience
- Lori Ciccone, Office of Sponsored Programs
- Allison Sahl, Office of Faculty Affairs
- Mark Guadagnoli, School of Medicine
- Jill Zimbelman, Co-Chair, Office of Research Integrity
- Haroon Sahotra, Co-Chair, Office of Faculty Affairs
- Zach Miles, Office of Economic Development.
- DeLyle Bowen, Office of Faculty Affairs
- Susan VanBeuge, Faculty Senate Representative of the Department of Nursing
- Chelsea Holmes, Office of Export Control
- Andy Stefik, Computer Science
Advisory Support
- Susan O'Brien, Office of General Counsel
Training
Training workshops on the topic of conflict of interest/compensated outside services and on issues related to the ethical conduct of research are regularly offered by the Office of Research Integrity.
Educational resources are also available online through the Collaborative Institutional Training Initiative (CITI):
Definitions of Terms
Frequently Asked Questions
Links
The following are links to policies, procedures, and other resources pertaining to conflict of interest/compensated outside services and related issues:
- UNLV Conflict of Interest/Compensated Outside Services Policy
- UNLV Conflict of Interest Rules and Procedures
- NSHE Board of Regents Handbook Title 4 Chapter 3, Section 9 (Professional Staff)
- NSHE Board of Regents Handbook Title 4, Chapter 10, Section 1.7 (Business Management – Conflicts of Interest Prohibited)
- NSHE Board of Regents Handbook Title 4, Chapter 12 (Intellectual Property, Research, and Entrepreneurial Activity)
- Nevada Revised Statutes Chapter 281A.400-430 (Code of Ethical Standards)
- Nevada Revised Statutes Chapter 396 (Nevada System of Higher Education)
- State of Nevada Commission on Ethics Consanguinity/Affinity Chart
- Code of Federal Regulations, Including 42 CFR Part 50, Subpart F (Promoting Objectivity in Research)
- Code of Federal Regulations, Including 45 CFR Part 94 (Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors)
- NSF Proposal and Award Policies and Procedures Guide
- Guidance for Clinical Investigators, Industry, and FDA Staff: Financial Disclosure by Clinical Investigators
Contact
Conflict of interest/outside compensated services policies and procedures are jointly overseen by the Office of Research Integrity and the Office of Faculty Affairs. For questions on conflict of interest/outside compensated services policies and procedures, please contact:
Haroon Sahotra, Associate Vice Provost of Faculty Affairs
- Phone: 702-774-3438
- Email: haroon.stephen@unlv.edu
Jill Zimbelman, Research Compliance Director, Office of Research Integrity
- Phone: 702-895-1862
- Email: jill.zimbelman@unlv.edu