Avoiding Conflicts of Interest


Policies and Regulations Applicable to Specific Categories of Augusta University Employees.

The following policies, rules and regulations apply only to specific categories of Augusta University employees.

Outside Professional Activities  Research Conflict of Interest State Purchasing Regulations VA Conflict of Interest

1. Outside Professional Activities 

Augusta University has implemented policies concerning outside professional activities. This policy does not apply to all employees, but does apply to all full-time faculty, as well as persons in administrative positions, regardless of whether they also have faculty appointments. It does not apply to non-exempt classified employees or part-time faculty. The policy basically acknowledges that employment at the Augusta University sets certain limits on outside professional activities. Specifically, employees covered by this policy are not allowed to engage in any outside activities within the realm of their professional expertise without first obtaining the approval of their department chair/division director and dean/Vice President. The OA-1 form must be filled out and approved in advance of any outside activity. In addition, a yearly summary of all outside activities must be submitted by each employee covered by this policy. Failure to obtain the appropriate approval or submit the appropriate annual report may result in disciplinary action.

The types of outside activities an employee may engage in, the total amount of time that may be devoted to such activities and the amount of remuneration the employee may receive for these activities are not specified in the policy. Rather, they are left to the discretion of the individual chair, division director, dean and vice president. As a general rule, employees engaged in outside activities will be required to do so on their own time. That is, they may do it during times when they are not expected to be providing services to the institution or when they have taken appropriate leave. Generally, it is not necessary to obtain approval for an outside activity where no remuneration is received.

It is important to note that approval of an outside activity applies only to the activities of the individual employees submitting the OA1 and OA2 forms. Any use of ancillary support or of the facilities, supplies or equipment of Augusta University must be separately requested and approved. Additionally, Augusta University will expect full compensation for the value of those services, facilities or supplies.

2. Research Conflict of Interest

To ensure the integrity and objectivity of research and other scholarly activities of Augusta University employees, Augusta University has enacted a policy requiring the disclosure of all financial conflicts of interest on the part of the principal investigator, co-investigator, or any other person, (e.g., post doctoral fellow) responsible for the design, conduct or reporting of research or scholarly activities which are funded or proposed for funding by a sponsor. "Significant financial interest" is defined to mean anything of monetary value including salary, equity interest, (e.g., stock or stock options) and intellectual property rights (e.g., patents or copyrights). All persons submitting a proposal for review and approval through the Division of Sponsored Program Administration will be required to sign a statement indicating whether or not they have any significant financial interest. This disclosure is included on the "Division of Sponsored Program Administration Routing Sheet" (the so-called "purple sheet"). It must be signed by the principal investigator. Any disclosure must be updated by the investigator if at any time there is a change in the facts reported in the initial disclosure. For instance, if no conflict of interest existed at the time of the initial proposal but such a conflict arose during the course of the project or proposal, the investigator must file a disclosure of conflict of interest as soon as those facts become known to him or her. Upon disclosure of a significant interest, the department chair or other "responsible representative of the institution" will determine whether or not the conflict may be resolved. The policy offers numerous alternatives for resolution of conflicts of interest including public disclosure, monitoring, modification of the research plan, disqualification of the researcher from participation, and divestiture of any financial interest.

Penalties for failing to comply with this policy include all the same disciplinary action available for violation of any Augusta University policy. Additionally, if any federal funds are involved, federal regulations may apply which carry penalties including financial penalties, a ban of the investigator from applying for future grants and significant penalties against Augusta University. Learn more by visiting the Policy Information page.

3. State Purchasing Regulations 

Augusta University employees engaged in purchasing and procurement activities are subject to regulations related to state purchasing. These restrictions are in addition to those applicable to other employees at Augusta University. These policies may be found in the State Purchasing Manual available in the Supply Administration Division.

4. VA Conflict of Interest 

The U.S. Department of Veteran Affairs has recently amended its regulations regarding outside activities of VA employees. Employees of Augusta University who are also part-time employees at the VA should contact the VA Medical Center-Augusta for information on these regulations and their application. Individuals who may be VA employees but who are also full-time or part-time employees of Augusta University should be reminded that Augusta University policies still apply to them. The fact that an activity may be allowed under VA regulations does not automatically exempt the employee from the requirements of Augusta University policies and procedures.


Questions

This information is intended to serve as a reference and a guide to all employees at Augusta University in complying with the various rules and regulations and requirements discussed above. It is each individual employee's responsibility to ensure that they are in compliance with these policies. If there is a question regarding application or interpretation of any of these policies and procedures it should be directed first to the supervisor. If it is not resolved at that level, inquiries may be directed to Legal Affairs 706-721-4018.