Who is the Unit Executive Officer (UEO)?
The University Policy on Outside Activities and Conflicts of Commitment and Interest defines the “unit executive officer” (UEO) as the department head/chair, or equivalent officer of other units.
What are the responsibilities of a UEO in regards to COI?
The UEO has the duty to:
- Evaluate all potential conflict situations reported or known to them (including all requests for approval of non-University, outside activities) before approving the activities;
- Obtain sufficient information to make informed decisions under this Policy;
- Determine whether the application or use of University time or resources, if requested, is beneficial to the University’s mission. If UEO is not custodian of the resources, then the UEO must document the approval or agreement from the appropriate office that oversees the resources;
- When an actual or perceived conflict is identified, and a decision is made to allow the activity to proceed, develop an appropriate management plan with the academic staff member that specifies the review timeline;
- Implement management plans for activities that present actual or perceived conflicts of commitment or interest;
- When an actual or perceived conflict is identified and a management plan is implemented, route the disclosure and management plan for a second level of review;
- Using START myDisclosures, notify academic staff members within 14 days of the decision on a request for approval of the submitted RNUA;
- Monitor non-University activities of academic staff members and oversee and regularly evaluate/update management plans; and
- Notify appropriate University offices if the actual or perceived conflict results in a performance issue, misuse of University resources, or a violation of University policies and/or procedures.
Does a Discloser have appointments in multiple units? Multiple Unit Executive Officers (one from each unit) must review and approve the Non-University Activities
- When an academic staff member holds paid appointments in multiple units, the UEO of each unit must review and approve the academic staff member’s disclosures and requests for prior approval of non-University activities. The UEO of the academic staff member’s home unit takes the lead in this process. When a second level of review is required, it follows the regular reporting line based on the home unit.
- If a UEO does not approve the proposed activities or the management plan, a second level of review must occur, and the decision on second-level review will be final, subject only to appeal on procedural grounds.
Revoking Approval
- If at any time, the UEO perceives that the conflict management plan mechanisms are no longer effective, the UEO must revoke approval of the non-University activity and work with the academic staff member to evaluate the situation and revise the management plan.
- The UEO of the home department shall inform the UEO at the second level when a management plan has been revoked.
Second Level of Review
A second level of review is required for any activities or relationships presenting an actual or perceived conflict of commitment or interest. The review takes place at the next administrative level above the academic staff member’s home department. For example, the dean of a college completes the second level of review when a department head determines an actual or reasonably perceived conflict of commitment or interest exists.
The administrator at the second level of review has the duty to:
- Review the proposed activities and management plan;
- Request additional information, as needed, prior to approving the management plan; and
- Work with the academic staff member and first level UEO to finalize a management plan.
The second level of review is not an appeal but is a routine part of the process. The administrator at the second level review is required to work with the administrators at the first level review when the second level reviewer has concerns about the activities reported, the first level reviewer’s assessment of the conflict of interest or commitment, and/or the proposed management plan.
What are the responsibilities of a UEO regarding conflict management?
A conflict management plan is a written understanding of the situation that gives rise to a conflict of commitment and/or interest and the management mechanisms that will be implemented to mitigate or eliminate the conflict.
Creating, implementing, and monitoring a conflict management plan is a collaborative effort among the academic staff member, their department chair or head and dean, a management oversight committee, departmental staff, and the conflict of interest officer.
For more information, visit the Creating a Conflict Management Plan (CMP) page and Guidance on Conflict Management Mechanisms for UEOs.