Implementing the Individual Business or Financial Conflict of Interest Board of Regents Policy FAQ

1. Why do I need to complete a ROC (Request for Outside Consulting) if I’m already declaring the consulting on the REPA?

   ROCs and REPAs serve different purposes. A ROC is the electronic form used by faculty and P&A staff to obtain prior approval to participate in outside commitments. These commitments cannot interfere with the performance of their regular University duties. (See Administrative Procedure: Outside Consulting and Other Commitments by Faculty and Academic Professional and Administrative (P and A) Staff)

   A REPA is the electronic form used by filers to disclose external relationships. These relationships are reviewed by committees to ensure that any identified conflicts of interest are appropriately managed, reduced, or eliminated. (See Administrative Procedure: Disclosing Potential Individual Conflicts of Interest)

2. How significant does a change in my external relationships need to be to trigger the filing of a mid-year REPA?

   There's no perfect answer. As a general rule, if any of your answers to the core questions changes from "NO" to "YES," you should file a mid-year REPA. Also, if you enter into in a consulting arrangement with an entity that also funds research in which you’re engaged, a new REPA should be filed. If you need assistance in determining whether or not a new REPA is needed for your particular situation, contact the Conflict of Interest Program Coordinator at REPAmail@umn.edu.

3. If the work I'm doing for a company is just as a presenter, does this count as consulting?

   Consulting, for purposes of filing a REPA, is broader than the situations in which a formal consulting agreement is entered into. Presenting or speaking for an entity that is not a public or nonprofit entity is consulting, just as is attending meetings in which your expertise and contributions are valued.

4. If there's currently a management plan in place for me, when is the file closed?

   The file remains open until the situation that gave rise to the conflict ends. If your circumstances change, you may contact the Conflict of Interest Program staff to determine whether the management plan can be retired or modified.

5. I have owned stock in a company for many years. This company makes products that the University purchases and uses at an enterprise level. I owned the stock before I came to the U. Do I need to disclose that on the REPA?

   A financial interest, such as stocks, or income from a business that relates to your University activities must be reported regardless of the amount or % interest.

6. What professional services are required to be reported?

   If the services provided are in the field of expertise for which the University hired you, these commitments must be included in the REPA. There is a short list of activities exempt from disclosure and these are found in Administrative Procedure: Disclosing Potential Individual Conflicts of Interest (section VI.)

7. How are the number of days computed for outside commitment purposes?

   The length of a day is considered the length of a faculty member's normal working day, up to ten hours. However if the entity the individual is consulting with defines "day" differently, the individual must use that definition (e.g., in its consulting agreements, the Veteran's Administration defines a day as 8 hours). So, if you have commitments during the year for a total of 40 hours, this would equal 4 days (at a normal work day of 10 hours).

8. Who do I contact to get additional questions answered?

   The first point of contact for filers is the Conflict of Interest Program Coordinator, who may be reached at REPAmail@umn.edu or 612-626-1462. If you need technical assistance while completing a REPA, please call the EGMS helpline at 612-624-1600.