Printed on: 05/20/2018. Please go to http://policy.umn.edu for the most current version of the Policy or related document.

ADMINISTRATIVE PROCEDURE

Reporting External Relationships and Business and Financial Interests

Overview

In order to timely identify and manage conflicts of interest, covered individuals are required to complete a Report of External Professional Activities (REPA) annually, and within 30 days of a change in circumstance. 

A. Annual Reporting

  1. Notices to covered individuals.
    1. From the Conflict of Interest (COI) Program.
      1. Annually the Conflict of Interest Program sends an email notification to covered individuals requesting that they complete a REPA by a designated deadline.
      2. Throughout the year the COI Program identifies new covered individuals and sends email notifications shortly thereafter requesting completion of a REPA by a designated deadline.
      3. The COI Program may send one reminder email to covered individuals who fail to file a REPA by the designated deadline. Thereafter the COI Program will work directly with the covered individual and/or the covered individual’s supervisors until the disclosure requirement is met.  
    2. From Sponsored Projects Administration (SPA). All principal investigators, co-investigators, and key personnel must have a current year REPA on file at the time of proposal submission (for internal and external sources of support).  If an investigator or a key person does not have a current year REPA on file, SPA will notify the individual of the filing requirement.
  2. Covered individual responsibilities. The covered individual must file a timely, accurate, and complete REPA that includes all significant financial interests and business interests in a business entity that are related to their University expertise and responsibilities. A REPA must be filed even if the covered individual has no outside activities or significant financial interests or business interests to report. Covered individuals engaged in PHS-funded research must disclose significant financial interests and business interests no later than at the time of application for PHS funded research.
    1. Electronic REPA using the Electronic Grants Management System (EGMS). University employees with an employee ID must use the EGMS to file a REPA electronically.
      1. A covered individual may delegate to a University employee the task of completing a covered individual’s REPA. However, once completed the REPA will be routed to the covered individual for review and approval. The covered individual must be recognized as an approver in EGMS, and should call the REPA helpline at (612) 626-1462 to establish this approval authority.
      2. The covered individual or delegate completes all applicable fields/questions on the REPA to report outside consulting or other commitments pursuant to Administrative Policy: Outside Consulting and other Commitments, and significant financial interests or business interests pursuant to the thresholds as defined in this procedure.
      3. The covered individual submits the electronic form for review by the appropriate departmental, collegiate, or unit approvers. If a delegate completed the REPA, it will be routed to the covered individual for approval as an accurate and complete disclosure before the REPA is electronically routed to their designated approver(s).
      4. If the covered individual has the REPA returned by an approver/reviewer for additional information, the covered individual shall provide the necessary information and resubmit the REPA.
    2. Paper REPA. Covered individuals who are unable to access the electronic REPA through the EGMS will complete a paper copy of the REPA and submit the completed form to the COI Program. Covered individuals needing a paper REPA should call the REPA helpline at (612) 626-1462.  

B. Change in Circumstance Reporting

A covered individual must file a change in circumstance REPA within 30 days of the occurrence of any of the following:

  • an increase in the value of an existing financial interest, or the acquisition of a new financial interest, that qualifies as a significant finance interest related to a covered individual’s University expertise and responsibilities;
  • the assumption of a paid or unpaid business interest (executive or board position) in a business entity that is related to a covered individual’s University expertise and responsibilities;
  • a change in University responsibilities (e.g., a new research project) that relates to a business or significant financial interest; or
  • (For PHS sponsored researchers only) travel related to one’s University responsibilities valued in excess of $5000 paid for or reimbursed by an entity unless the travel was paid for or reimbursed by a governmental agency, an Institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.

If the covered individual has filed an annual REPA, the covered individual should access the REPA through the EGMS, select “Change in Circumstance” as the reason for filing, and report the new information on the REPA.

C. Financial Interest Reporting Thresholds

  1. For a covered individual involved inclinical health care, or who is responsible for the design, conduct, or reporting of research funded by, or applied for from, the Public Health Service (PHS). A covered individual must aggregate their financial interests in a business entity with those of their family members and report them on a REPA if they (1) reasonably appear to be related to the individual’s University expertise and responsibilities and (2) meet the following thresholds:
    • Aggregated remuneration and equity interest in a business entity exceeding $5000;
    • Aggregated royalties from a business entity exceeding $5000;
    • Any equity interest held in a non-publicly traded business entity;
    • For PHS sponsored researchers only: travel valued in excess of $5000 annually paid for or reimbursed by an entity unless the travel was paid for or reimbursed by a governmental agency, an Institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education. The covered individual must disclose the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration.  
  2. For all other covered individuals. A covered individual must aggregate their financial interests in a business entity with those of their family members and report them on a REPA if they (1) reasonably appear to be related to the individual’s University expertise and responsibilities and (2) meet the following thresholds:
    • Aggregated remuneration and royalties from a business entity exceeding $10,000;
    • An equity interest that exceeds $10,000 as determined through reference to public prices or other reasonable measures of market value, or represents more than a 5% ownership interest in a business entity.

D. Reporting of Certain Financial Interests Not Required

Covered individuals are not required to report the following financial interests on a REPA:

  1. Salaries or other remuneration paid by the University to the covered individual. 
  2. Income from a private practice plan or private professional practice plan pursuant to Board of Regents policy.
  3. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an institution of high education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
  4. Income from service on advisory committees or review panels for a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
  5. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the covered individual does not directly control the investment decisions made in these vehicles.

E. Business Interest Reporting.

When related to the individual’s University expertise and responsibilities, a covered individual must report on a REPA the holding of any executive position (e.g. President, Vice President, Chief Executive Officer, Chief Operating Officer, Treasurer, Chief Scientific or Technical Officer, Artistic Director) for a business entity, or membership on a board of a business entity, whether or not such activities are compensated. The term "board” includes board of directors, board of trustees, scientific advisory board, medical advisory board, and advisory boards.

F. Enforcement

If a covered individual fails to file a required REPA, or files an incomplete, erroneous, or misleading REPA, or fails to provide additional information as required by a Conflict Review Panel or COI Program staff, the Chief Compliance Officer may pursue administrative sanctions. Failure to file a REPA or failing to report in good faith may result in the delay or denial of approval for human participant research, the processing of a sponsored project proposal, or the expenditure of sponsored project funds. The covered individual also may be subject to disciplinary action, consistent with applicable University policies and procedures.

Document Feedback