Disclosure of Conflicts of Interest and Commitment 200506 Awareness

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Disclosure of Conflicts of Interest and
Commitment2005-06 Awareness

• Debbie Hunt Special Advisor for Audits and
  Assessments
• Matt Ronning Associate Vice Chancellor for
  Research and Compliance

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Why disclose?

• Mitigate risk to the disclosing party and to the
  institution
• Maintain confidence in NCSUs self-regulation of
  inherent and natural conflicts of interest
• The criminal statute of NC, NCAA regulations, and
  UNC System Policy

3
Who discloses

• Every EPA employee
• All EPA Professionals
• Coaches
• and Faculty in the colleges

4
What is disclosed?

• Significant financial interests
• 10K and more than 5
• Example Sports camps
• Associations with outside entities
• As it may involve/influence decision-making as a
  University employee
• Note Disclosure encompasses employee or family
  member living in same household

5
When to disclose?

• Renew comprehensive disclosure annually late
  summer In process now (July 2005)
• Update disclosure perpetually throughout the
  disclosure year
• As circumstances change
• Watch for EPAP that creates a COI and update COI
  accordingly
• EPAP system now electronic and integrated with
  COI

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How/Where?

• All covered employees must utilize the web system
• New system guides employees to answer only
  required questions based on each response given
• Approvals and certifications are electronically
  routed to the Athletic Director instantaneously

• http//www.ncsu.edu/sparcs/coi

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Management Plans

• When a real or perceived conflict exists
• Establish parameters of operating with the
  conflict
• Eliminate conflicts if management is impossible
• Management plans should naturally fall out of the
  disclosure itself

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Management Plans Examples

• Example 1
• Athletics EPA employees spouse serves on the
  board of directors of the Boys and Girls Club and
  this organization rents NCSU athletic facilities.
• Employee will not be involved in any
  decision-making/scheduling for rental of
  facilities or assignment of facilities to Boys
  and Girls Club. All such decisions will be
  elevated to the employees supervisor or the
  athletic director.

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Management Plans Examples, cont.

• Example 2
• Athletics EPA employee is co-owner of Gymnastics
  R Us, where some NCSU students or SPA employees
  work part time on the weekend.
• EPA Employee does not directly supervise these
  students or SPA employees either at NCSU or at
  Gymnastics R Us. Recruitment is open to all NC
  State students and employees.

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Consequences

• Consequence of compliance is mitigation of risk.
  
• Consequences of non-compliance include NCAA
  sanctions, termination of employment, criminal
  prosecution.

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Disclosure Maintenance

• Subject to increasing audit oversight
• Ensure all disclosures are current
• Watch out for new hires
• COI System is a personnel file
• Appropriate personnel should have access
• Discuss COI at least twice per year at Athletics
  staff meetings and via other forms of
  communications that prove effective in your
  division

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External Professional Activities for Pay Notice
of Intent

• aka NOI and EPAP
• Why, When and How

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Request Permission for EPAP

• NCAA Rules Require Full Disclosure of EPAP
• State of NC rules prohibit EPAP without
  justification and consideration by the agency
  head
• EPAP is a privilege enjoyed by academic
  institutions and must be carefully monitored

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When to Request Permission

• At least 10 calendar days prior
• Exceptional circumstances can arise. When you
  cant meet the 10 day rule, then make certain you
  submit the request anyway for consideration by
  administration.
• After the fact, still need to do it but need
  extra-ordinary justification.

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How to Request Permission

• Web Based Utility
• Fully integrated with COI
• Routes automatically to Directors office and
  where relevant Chancellors office.

http//www.ncsu.edu/sparcs/coi/
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Questions

• Ask questions now
• Contact Matt Ronning (513-2148) or Debbie Hunt
  (515-7512) in Research Administration
• Submit questions via web at http//www.ncsu.edu/re
  search/guide/questions.html