Conflict of Interest/Outside Activities

For Faculty

UF COI Program/eDisclose

As a condition of your employment with the University of Florida (UF), you are required to follow UF guidelines, policies and procedures regarding conflicts of commitment and conflicts of interest.

At UF, there is one COI Program, policy and a new electronic disclosure system (eDisclose). The process for review and approval of Outside Activities and Financial Interests are established in UF Policy 1-003: Conflicts of Commitment and Conflicts of Interest and administered by the UF COI Program. For more information, check out the Resources page forFAQs and helpful guides for disclosers and reviewers.

Revised UF Policy 1-003 consolidates three areas of COI:

  • Conflicts of Commitment
  • Conflicts of Interest
  • Research Financial Conflicts of Interest

Key Points for UF Policy 1-003

  • Establishes the expectations, requirements and processes for UF employees
  • Policy excludes employees with UF Health, Direct Support Organizations (DSOs), and any related or affiliated entities
  • Employees must receive approval prior to engaging only in select subsets of activities
  • Employees must report actual disclosable interests as defined under UF Policy 1-003

Disclosures will be required via eDisclose system for:

  • Pre Approval Requests (PAR) of a limited set of outside activities
  • Disclosable Interests on the Disclosure Profile
  • Completed outside activities
  • Obtained financial interests (e.g., equity or payment for services)

UF Policy 1-003 requires the reporting of Disclosable Interests for equity, consulting or other professional services, intellectual property rights, divestiture and cash pay-out, sponsored or reimbursed travel, board service, outside employment, other appointments, and innovation inducement prizes. See UF Policy 1-003 for full definition of each category.

Disclosable Interests must be disclosed on your “Disclosure Profile” in eDisclose. The Disclosure Profile is a dedicated workspace for you to report all your interests in one place that is kept updated throughout the year and certified at least annually.

  • Disclosure is required if the Disclosable Interest is related to an employee’s area of expertise at UF.
  • Disclosable Interests held by the UF employee or their Immediate Family must be disclosed.
  • The Disclosure Profile must be certified annually (you will also receive a system notification reminder).
  • Disclosable Interests must be added to the Disclosure Profile within 30 days of acquisition or discovery.

UF COM – COI Policies and Covenants

UF Regulation Number: 5.0764: College of Medicine Policy on Pharmaceutical, Medical Device, and Biotechnology Industry Conflicts of Interest and Policy on Industry Academic Relations

The College of Medicine’s conflicts of interest policy applies to COM personnel at UF. Under COM’s COI Policy on Industry Academic Relations, all interactions between COM personnel and Industry must conform with the policy on specific activities, including:

  • Gifts
  • Pharmaceutical Samples and Educational Materials
  • On‐Site Access by Industry
  • Continuing Medical Education (CME) and Other Educational Activities
  • Travel to Meetings/Honoraria for Attendance
  • Authorship
  • Scholarships and Fellowships
  • Prohibition on Speaker Bureaus
  • Restrictions on Food/Entertainment

Additional restrictions on faculty clinical practice are regulated under College of Medicine: Clinical Faculty Teaching Appointments and Restrictive Covenants.

Outside clinical (patient care) activity by a faculty physician within a fifty-mile radius of the site of the faculty physician’s major clinical assignment is not authorized.