Academic and Researcher Conflicts of Interest & Commitment Policy and Standards
Download COIC Policy (PDF) Download Procedures & Guidelines (PDF)
Note: To make disclosure requirements more consistent, CU Boulder’s COIC policy has been updated to set new dollar value thresholds for 2023 above which significant outside financial interests such as salary, consulting fees and equity must be disclosed.
Forms & Useful Links
Please note: Some of these forms take a little time to download. Your patience is appreciated.
To be used by disclosers who have a MOU with a monitoring component; to be completed and returned to the COIC Office in conjunction with annual DEPA submission, or when otherwise requested. The discloser's signature is required.
Each campus within the University of Colorado system has its own office for Conflicts of Interest, and reporting system. See the following links for the non-Boulder campuses:
Use of Self-Authored Instructional Material Approval Form
During the DEPA reporting process, disclosers are asked to certify that department approval has been obtained for self-authored instructional material that is required in classes taught at CU. Copies of this approval form remains housed with the discloser and department (if required); it is not submitted to the COIC Office.
Affiliations with non-U.S. entities require special considerations. The COIC disclosure form solicits this information. All such affiliations must be reported during the application of federally sponsored projects, and the Export Control Office must be contacted for affiliations involving federally sanctioned/embargoed countries. Federal notices can provide additional information.
NIH Notice 7.2019 NSF Letter 7.2019 Dept. of Justice 8.2019 CU Boulder Updates
Specific information about consulting/engaging in professional activities outside of the university can be found by job classification in the sections entitled "Outside Employment". Additionally, university employees in academic/research positions are responsible for:
- providing updated disclosure reports (DEPAs);
- including the Standard Addendum for Consulting and Third Party Employment into external agreements in order to avoid conflict with the University's Intellectual Property policy;
- being aware of the roles/responsibilities and limitations related to graduate student involvement in faculty affiliated entities.
- note that the Director of the Office of Conflicts of Interest & Commitment may be asked by businesses/parties external to the University to formally verify the status of a discloser. Brief letters, memos, notices, and form completions are typically acceptable types of documentation that may be provided. However, the University will not review nor enter into legally binding agreements / other types of legal instruments where official University business is not involved, even if those instruments appear to be primarily for the purposes of verification.
Consulting Approval Form (1/6th Rule). During the DEPA reporting process, disclosers are asked to certify that department approval for "consulting" (up to 1/6th time) outside of the University has been obtained. Pertains to all faculty titles: Research Associates, Professional Research Assistants, Research Professors, tenured & tenure track faculty, instructor rank faculty as well as administrators with faculty rank. Copies of this approval form remain housed with the discloser and department; it is not submitted to the COIC Office.
Guidance on Outside Employment for Graduate RAs
Additionally, be certain to review the Conflicts of Interest and Graduate Student Primer.
Officer Disclosure via the Campus Controller's Office (See Section III Procedures, Forms, etc.)
Officers who are also faculty must satisfy two disclosure and approval processes:
- The routine Officer Disclosure via the Campus Controller's Office
- DEPA reporting
See Policy 3B: Conflict of Interest—University Staff and Recusal Guidance
Classified Staff: Use form Multiple Classified Appointments
All university employees other than those with faculty titles (Research Associates, Professional Research Assistants, Research Professors, tenured & tenure track faculty, instructor rank faculty as well as administrators with faculty rank): Use form Request to Engage in Outside Employment
Use/sharing of university space and facilities for non-university research requires review and approval per the process outlined.
Private Use Space Request Form
Contacts: Kimmi Pepitone, Steven Stasica and Rebecca Fell
These types of Service Activities are other sponsored activities performed by university personnel and utilize university facilities and/or equipment with excess capacity to perform work similar to tasks done on sponsored research projects, but without the scientific investigation and conclusions. Examples: work for hire/consulting, analysis and interpretation, external training, etc. COI reporting is a required component of these kinds of activities.
Venture Partners at CU Boulder (formerly Technology Transfer Office)
For information governing: Consulting, Intellectual Property (IP); patents/ licensing/copyrights/trademarks for discoveries/inventions/educational materials and software; start-up company development; materials transfer agreements. Brynmor Rees is the primary contact for Venture Partners issues related to Conflicts of Interest at CU Boulder.
Please refer to the Boulder Faculty Assembly Handbook; Part II Professional Responsibilities, Ethical Principles, & Faculty Conduct; Section A: Teaching and Students; Ethical Principles; 1. Expected Conduct, items m and n.
Processes Related to Potential Fiscal COIs, Overseen by the Controller's Office
Purchasing and Fiscal Conflicts of Interest
See: Procurement Service Center (PSC) Conflict of Interest Evaluation Form
Gifts and Donations; Gift Funds; Gifts in Kind
See: Campus Controller's Office FAQs and Gift-in-Kind Acceptance Form
Accepting of Sponsorships; Advertising; Fundraising
See: Campus Controller's Office FAQs and Sponsorships