University of Illinois System
Executive Vice President/Vice President for Academic Affairs

The following COCI procedures apply to the University of Illinois Urbana-Champaign and the University of Illinois Springfield and the system offices. Procedures for the University of Illinois Chicago can be found here. 

 

I. Procedures

University of Illinois Urbana-Champaign, University of Illinois Springfield and the system offices will conduct a coordinated annual disclosure and review process for conflicts of commitment and interest among its covered individuals to meet the requirements of law and of research sponsors. These processes will be conducted through the University’s online reporting tool, START myDisclosures, using the Report of Non-University Activities (RNUA). 

For the purposes of START myDisclosures and the RNUA, Non-University Activities are equivalent to Outside Activities as defined by the University’s Policy on Outside Activities and Conflicts of Commitment and Interest. See START myDisclosures.

A. Covered Individual Responsibilities 

  1. Covered Individuals have the duty to request and obtain approval from their UEOs prior to engaging in Outside Activities including:

    Any financial interest, appointment, affiliation, entrepreneurial activity, employment, fiduciary role in an association, or Sponsored or Reimbursed Travel of the Covered Individual with an entity other than the University that reasonably appears related to or competes with the Covered Individual’s University Responsibilities or the University’s mission of education, research, public service and economic development, regardless of compensation or level of financial interest. Outside Activities may be, but are not necessarily, formalized through a written agreement.
     
  2. Covered Individuals will complete or update the RNUA, even if no activities are reported:
    1. Upon the start date of a new hire or within 30 days of the start of a new hire University appointment; 
    2. when requesting approval from the UEO for a new Outside Activity; 
    3. when a change in Outside Activity occurs; 
    4. when required by granting agency; and 
    5. annually during the coordinated disclosure process.
  3. When requesting approval for an Outside Activity and completing or updating the annual disclosure, the Covered Individual will describe:
    1. the time commitment to the activity; 
      • Covered Individuals whose University appointments are less than 50% FTE are required to disclose their Outside Activities, but are not required to report the time commitment for those activities.
    2. the role of the Covered Individual with the entity, if any;
    3. whether the entity, if any, did/does business with the University;
    4. whether any other University of Illinois faculty, staff, or students were/are involved in the activity or relationship; and
    5. whether any University resources were/are used by the entity.

      Conflicts of interest can arise from a Covered Individuals’ Outside Activities that occur outside their university appointment periods. Covered Individuals must report activities even if the activities are conducted outside of the University contract period. When the activities occur outside of the University contract period, the Covered Individual is not required to report or request time. 
       
  4. Temporary Releases from Reporting Outside Activities During the Annual Disclosure Process
    1. In cases where a Covered Individual is unable to complete the annual RNUA due to medical leave or a University-approved unpaid leave, the UEO may grant a temporary release to the Covered Individual. The release exempts the Covered Individual from completing the RNUA disclosure until their return to work. 
    2. If granted a temporary release from the RNUA disclosure, the Covered Individual must comply with the applicable University leave policies. If the Covered Individual engages in Outside Activities that had not been approved under the leave and/or if changes to Outside Activities reported on the RNUA occur during the leave, he or she must complete the RNUA to disclose the Outside Activities at the time that the previously unapproved activity is initiated.
    3. A UEO may not grant a temporary release to a Covered Individual from reporting if they continue to conduct, administer, or apply for a sponsored project while on leave.
    4. The UEO must ensure that any Covered Individual who is excused from reporting completes the RNUA upon return to work.
    5. The UEO can revoke the release at any time.

See START myDisclosures Users’ Guide.

B. Reviewer Responsibilities

RNUAs are first reviewed by the UEO. If the UEO determines that the activity disclosed could or does present a conflict of commitment or interest, the UEO will forward the approved RNUA, along with a proposed management plan, to the next administrative level for a second level of review. 

i. Unit Executive Officer (UEO) Responsibilities

The UEO has the primary responsibility to enforce the Policy, and that responsibility may not be delegated. The UEO or Covered Individual may seek, at any time, the advice of the dean, director, responsible official, or other individual responsible for the process that generated the disclosure. The UEO will work with the Covered Individual to identify, evaluate, and either manage or eliminate actual or perceived conflicts prior to forwarding the RNUA for the next administrative level for a second level review. 

a. The UEO has the duty to:

  • Evaluate all potential conflict situations reported or known to them (including all requests for approval of 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 the UEO reviewing the disclosure 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 Covered Individual 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 Covered Individuals within 14 days of the decision on a request for approval of the submitted RNUA; 

  • Monitor Outside Activities of Covered Individuals 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.

b. Multiple Unit Executive Officers

  • When a Covered Individual holds paid appointments in multiple units, the UEO of each unit must review and approve the Covered Individual’s disclosures and requests for prior approval of Outside Activities. The UEO of the Covered Individual’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.

  • UEOs of units in which Covered Individuals hold “courtesy” appointments will have access to the RNUAs of those appointees but will not approve or deny Outside Activities.

c. 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 Outside Activity and work with the Covered Individual 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.

ii. Second Level of Review

A second level of review is required for any Outside Activities presenting an actual or perceived conflict of commitment or interest. The review takes place at the next administrative level above the Covered Individual’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.

  1. 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 Covered Individual and first level UEO to finalize a management plan.
  2. 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.

iii. Responsible Official

As the individual responsible for overseeing the implementation of the Policy, the Responsible Official has the duty to:

  1. Oversee and approve management plans prior to execution of licensing agreement for intellectual property and technology owned by the University;
  2. In cases of non-compliance, enforce compliance with the University policy;
  3. When activities are denied by the second level of review, serve as the arbiter of the appeal and make final determination on the review;
  4. Ensure that any requirements for reporting of significant financial interests or conflicts of interest imposed by laws, regulations or contracts are met;
  5. Report to external agencies, when required by law or contract;
  6. Provide external agencies access to relevant documents for investigations or audits, when required by law or contract; and
  7. Comply with public disclosure requirements of external agencies, when required by law or contract.

C. Conflict Management Plans

Conflict management involves the completion of an annual disclosure and approval process; and may require the execution of a written conflict management plan.

See RNUA Terms and Conditions

 

  1. Conflict management plans must implement mechanisms and oversight to address, at minimum, the following:
    1. Time spent on the Outside Activities;
    2. The potential involvement of students and/or other University employees in the activities;
    3. The potential use of University intellectual property or any other use of University resources;
    4. The relationship of an Outside Activity to a Covered Individual’s University duties or responsibilities; and
    5. The potential for diversion of funding opportunities to an outside entity.
  2. Conflict management plans must be reviewed and approved by the UEO and the administrator at the second level of review.

D. Recusal and Confidentiality

Any UEO or administrator at second level of review involved in negotiating or administering conflict management plans must disclose in writing to the next administrative level any actual or perceived conflict that they have in the matter. If such a conflict is disclosed, the conflicted party may not participate further in the process, and the responsibility for conflict management then passes to the next administrative level.

All parties to the evaluation, management, and approval of conflicts are to make diligent efforts to maintain the confidentiality of personal or proprietary information to the extent allowed by law. 

E. Appeals

Academic staff have the right to appeal decisions that would require the Covered Individual to eliminate, in full or in part, the Outside Activity.

See COCI Appeals Procedures.

F. Conflict Review Committee

In matters of conflict of commitment or interest, the Responsible Official at each university will be advised by a Conflict Review Committee. When appropriate for conflict issues involving System Office staff, the President's designee will be advised by a System Conflict Review Committee, composed of University experts where relevant and System representatives.

G. Reports from Third Parties

Individuals who question whether a Covered Individual’s Outside Activity has been appropriately disclosed and managed should bring their concerns to that Covered Individual’s UEO. In cases where the UEO is involved in the Outside Activity, individuals may bring their concerns to the Responsible Official or designee. 

H. Non-compliance

If an Outside Activity was not disclosed, a conflict was not managed in a timely manner, or if a Covered Individual failed to comply with a conflict management plan, the Responsible Official, in consultation with human resources and/or other appropriate University offices, will oversee a retrospective review, mitigation report or other procedures required by law.

See Retrospective Review.

See Legal and Policy Authorities.

I. Interim Administrative Actions

At any time after a potential conflict of interest or commitment has been identified and before final disposition of the case, the UEO may take interim administrative action as required to comply with the law, to protect the objectivity of research, to protect the interests of students and colleagues, to preserve evidence, or to protect resources. Any interim action should be devised and taken as to create minimal interference with the University activities of the individuals involved, and in accordance with the University policies.

J. Records Retention

Conflict of interest files, including RNUAs and conflict management plans, must be retained and disposed of in accordance with State law. Departments must work with Records and Information Management Services (RIMS) to dispose of these records.

K. Exceptions

Any exceptions to the procedures described above shall be made only for good cause and with the approval of the chancellor/vice president of the respective university or the University of Illinois System President's designee for members of the University of Illinois System Offices.

II. Forms, Tools and Additional Resources

Glossary

START myDisclosures 

START myDisclosures Users’ Guide

START myDisclosures Reviewers’ Guide

RNUA Terms and Conditions

COCI Appeals Procedures

University of Illinois Policy and Rules for Civil Service Staff Rule 16.01 Conflicts of Interest

Business and Finance Policy and Procedure Manual, Section 7.7 Procurement Conflicts of Interest

University of Illinois Ethics Line

Retrospective Review

Disclosure Guidance

Guidance on Potential Conflicts with Affiliated Entities

COCI Appeals Procedures

1. Appealing Denials by the UEO

When the UEO denies a request to engage in an Outside Activity, a Covered Individual may appeal the denial to the second level of review within 14 calendar days after receipt of the notice of denial. In any appeal, the Covered Individual must present, in writing, the rationale for approval of the activity and may submit documentation or evidence supporting the appeal.

The administrator at the second level of review will evaluate the information provided, may request additional information from the Covered Individual or the UEO, and may seek advice from the Responsible Official or other individual responsible for the process which generated the disclosure. Ordinarily, the second level of review must respond to an appeal within 14 calendar days of receiving either the appeal or information provided in response to requests for additional information. The outcome of the appeal is the approval or denial of the request to engage in the external activities. If 14 days pass without the second level of review notifying the Covered Individual of the outcome of the appeal, the Covered Individual has the right to take the appeal to the next administrative level, in which case the second level of review will be terminated, and the next administrative level will rule on the appeal. The Covered Individual may choose not to take the appeal to the next level, and if so, any delay in being told of the outcome by the second level of review will not be considered a procedural violation.

Denial of approval of an Outside Activity following an appeal to the second level of review is final, absent an appeal to the President or designee on procedural grounds.

2. Appealing Denials Initiated by the Second Level of Review

When UEO approval of an Outside Ay by the Responsible Official is final, absent an appeal to the President's designee on procedural grounds.

3. Final Appeals Based on Procedural Grounds

Appeals on procedural grounds must be filed with the President's designee within 14 calendar days after the Covered Individual receives notice of the denial by the second-level reviewer. The appeal must include a description of the procedures that were violated and may include documentation or evidence supporting the claim of procedural violation. The President's designee shall, within 30 calendar days, either affirm or vacate the decision to deny approval of the Outside Activity, and notify the Covered Individual and others concerned. This decision shall be final. In making a decision on an appeal, the President's designee will consider the University's obligations and interests as stated in this policy and whether fundamental fairness was afforded to the Covered Individual. The President's designee will also consult, if possible, with the chair of the appropriate University-wide or System Office advisory committee that represents the interests of the Covered Individual prior to issuing a decision.

Retrospective Review

  1. An activity was not disclosed

    If a Covered Individual discloses Outside Activities after the activities have occurred and the staff member did not obtain prior approval for the activities, then the UEO must conduct the review of the activities retrospectively.
    1. The UEO must obtain from the Covered Individual a written explanation that documents why the activities were not reported prior to engaging in the activities and indicates whether the activities will continue or have ended.
    2. The UEO must assess the retrospective disclosure and determine whether the retrospective activities present conflicts of commitment or interest; and whether mitigation is necessary.
    3. If the Outside Activities present conflicts of commitment or interest, the UEO must upload an explanation on how the conflict will be managed or eliminated, and the UEO must forward the RNUA for a second level of review.
    4. If mitigation is necessary, the UEO and Covered Individual will work together to mitigate the effects of the undisclosed activity and unmanaged conflict.
  2. A Covered Individual does not comply with the management plan
    1. The UEO must document a written explanation that details the circumstances surrounding the non-compliance. The UEO may consult with the Covered Individual for additional information.
    2. The UEO must assess the explanation and determine whether mitigation is necessary. If mitigation is necessary, the UEO and Covered Individual will work together to implement mitigation steps.
    3. The UEO must also consider, acknowledging past non-compliance, whether revoking approval for the activity is warranted.
  3. Conflicts are not managed in a timely manner
    1. The UEO will attach to the Covered Individual’s RNUA a written explanation detailing the circumstances surrounding the failure to manage the conflict(s).
    2. The administrator at the second level of review, in consultation with the Responsible Official or designee, will review the explanation and determine whether mitigation steps are necessary. 
    3. If mitigation is necessary, the UEO and Covered Individual will work together to mitigate the effects of the unmanaged conflict.

Guidance on Potential Conflicts with Affiliated Entities

The University of Illinois System strongly supports participation in activities external to a Covered Individual’s University role (“Outside Activities”) that comply with University policies, and applicable federal and state regulations. Outside Activities require prior approval and must be reported at least annually, and any approved Outside Activities deemed to be potential or actual conflicts must be managed appropriately. In evaluating the Covered Individual’s Outside Activities, the University must take into consideration that entities affiliated with the University may pose a greater risk for compliance with University policies. An entity, including companies, organizations, and individuals, is an “Affiliated Entity” when the entity proposes or has a contractual relationship with the University of Illinois, including contractual relationships for technology created through research at the University of Illinois. Any company that receives financial or other support from the University is an Affiliated Entity.

Covered Individuals who engage in Outside Activities with an Affiliated Entity offer valuable expertise, but inherently risk having a conflict of commitment or interest that must be managed appropriately. Any services provided to Affiliated Entities must be distinguishable from the Covered Individual’s University role and documented through the University’s disclosure procedures. Equity compensation from an Affiliated Entity may represent an unmanageable conflict of interest when job responsibilities are not clearly distinguishable. While Covered Individuals credited for creating Intellectual Property (IP) that is commercialized may be able to hold equity in an Affiliated Entity, Covered Individuals who work with an Affiliated Entity but are not credited on the IP face stricter standards, and in some cases may be prohibited from holding equity due to the nature of their University Responsibilities. Situations where Covered Individuals wish to hold equity in an Affiliated Entity will be evaluated on a case-by-case basis.

Updated 01/20/2026