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Conflict of Interest (COI)

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Annual Attestation

Annual attestation is the process to ensure compliance to the University of Utah’s Individual Financial Conflict of Interest Policy 1-006. This policy requires certain employees to file a financial disclosure to report whether they have any external business relationships (that reasonably appear to be related to their professional responsibilities to the University), so that potential financial conflicts of interest can be properly identified.

An updated disclosure must be filed at the start of each academic year (after July 1).  

These individuals must file a disclosure (even if they have nothing to report) in the Business Relationship Reporting (“BRR”) system, which is the institutional tool the University uses for financial disclosure processes across campus:

  • Faculty, excluding (a) emeritus faculty, (b) visiting faculty, and (c) adjunct faculty who do not hold an appointment in a Health Sciences school or college
  • Staff employed at the manager level or above
  • Staff with purchasing authority or delegated purchasing authority, including account executives and their delegates, staff authorized to use an institutional credit card (e.g., Purchasing Card or PCard), and staff authorized to make purchases through UShop. (Additional information can be found on the COI Office’s webpage – Guidance for Purchasers.)
  • Employees who participate in research, scholarly or educational activity, or transactions

See detailed training documents and help at https://oris.research.utah.edu/brr.php. 

NEW SOFTWARE

The software for BRR was upgraded in January 2025 to a revised software supported by the Office of Research Information Systems (ORIS). This upgraded system has increased data security and offers enhanced functionality over time. The site will look different, but all previous data will be maintained. As of late August 2025, there are new questions related to Research Security & Foreign Relationships which must be completed. 

TRAINING

Training is required this year for everyone due to new Research Security elements. You must complete training before filing a disclosure. 

COMPLIANCE FOR FILING A DISCLOSURE
 
Supervisors and other leadership can now help track disclosure compliance of their employees by accessing the ‘Compliance (Annual Attestation)’ tab in BRR. This feature is live and access to these individuals is already granted, based on HR data. Your dashboard there is tailored to your role in the organization structure. View disclosures from your group by clicking into the Attested column for more details. Please follow-up with employees who do not have a recent disclosure on file since July 1, 2025.
 
Additional personnel (as appropriately determined by supervisors) can be granted access to the dashboard if other support within the group is needed to assist in compliance monitoring (contact COI@utah.edu to request the “Compliance Champion” role and explain which org ID you are requesting).
 

DIRECT SUPERVISORS MUST APPROVE BUSINESS RELATIONSHIPS

For those who are part of Health Sciences, BRR is now the mechanism for direct supervisors to document their review and approval of their employee’s disclosures. This can only be performed by those who were listed as the discloser’s direct supervisor during the disclosure process. See the 'Supervisor Reviews’ tab in BRR to perform this activity. If the wrong direct supervisor was listed by mistake, contact COI@utah.edu to request that the supervisor review be reassigned (you should provide justification for this). 
 
Direct supervisors from other areas of campus should continue to independently document their reviews and approvals until this feature is released further.
 
See more about the process for employees to obtain approval for external business relationships on the COI Office’s FAQ page.
 

CONTACTS FOR SPECIFIC ISSUES/QUESTIONS:

 

Last Updated: 9/5/25