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UNC-CH Policy on Individual Conflicts of Interest and Commitment

The UNC-CH Policy on Individual Conflicts of Interests and Commitment describes the University’s approach and process for identifying, reviewing, and managing relationships to help assure the integrity of University academic and administrative endeavors. “Conflict of Interest” (COI) relates to situations in which financial or other personal considerations, circumstances, or relationships may compromise, may involve the potential for compromising, or may have the appearance of compromising a Covered Individual’s objectivity in fulfilling their University duties or responsibilities, including research, and teaching activities and administrative duties. “Conflict of Commitment” (COC) relates to an employee’s distribution of effort between University Duties or Institutional Responsibilities (primary and secondary), and external professional activities.

UNC-CH Policy on Institutional Conflict of Interest

The UNC-CH Policy on Institutional Conflict of Interest concerns conflicts that arise from the University’s financial relationships with external entities. It is intended to provide guidance to the Board of Trustees, administrators, faculty and staff to enable them to recognize and deal with institutional conflicts of interest, both real and perceived, that may arise in the course of relationships between the University as an institution and private entities outside of the University.

In addition to conflicts arising from individual investigator interests, the University’s financial holdings, intellectual property agreements, and the personal interests of its officials may give rise to conflicts of interest related to potential business transactions or research activities. The University is committed to ensuring the integrity of its decision-making processes.

UNC-CH External Professional Activities for Pay

The UNC-CH External Professional Activities for Pay defines external professional activities for pay (EPAP) as any activity that:

  1. is not included within one’s University employment responsibilities;
  2. is performed for any entity, public or private, other than the University employer;
  3. is undertaken for compensation; and
  4. is based upon the professional knowledge, experience and abilities of the EPA employee.

All Faculty and EPA non-Faculty employees are required to file a “Notice of Intent to Engage in EPAP” request through the online system at least ten (10) days before engaging in the external activity at

SOM/HCS Vendor Relations Policy

The SOM/HCS Vendor Relations Policy provides guidelines to the UNC Health Care System (UNCHCS) and the University of the School of Medicine (SOM) Covered Personnel on how to engage with Vendors in ways that protect personal and institutional integrity. Covered Personnel are required to disclose all financial relationships at the time of any proposed activity on the UNC AIR web site.

This Policy also provides guidelines around vendor-sponsored educational events. Coordinate the accounting aspects of vendor-sponsored events with the Finance and Business Operations Office.

UNC Health Affairs Code

The UNC FP Health Affairs Code states that all of its members’ professional fees and contractual income derived from and related to patient care, whether earned at UNC or in other locations, shall be billed, collected, budgeted, and expended through UNC Faculty Physicians. Professional income and fees shall mean all fees and professional income generated by members in the course of performing patient care services, including but not limited to direct patient care, patient care consultation, chart review, expert witness testimony, depositions., etc. Under certain conditions, medical/legal (e.g., service as an expert witness) activities and clinical moonlighting are now allowed to be pursued as an EPAP.  All Faculty and EPA non-Faculty employees are required to file a “Notice of Intent to Engage in EPAP” request through the online system at least ten (10) days before engaging in the external activity at

Use of University Resources

(Referenced in the UNC Policy Manual, the UNC-CH COI and COC Policy, and the Policy on Use of University Facilities for Non-Commercial and Commercial Purposes)

Employees may not use any University resources in support of EPAP activities, absent the occasional use of a computer and/or telephone. Under no circumstances may an employee use the services of another employee, student or trainee during University time or in their University role to advance the EPAP. Employees should also be wary of consulting arrangements through which they may risk sharing the confidential or privileged information of the University during the course of the EPAP.

UNC-CH Patent and Invention Policy

The UNC-CH Patent and Invention Policy governs UNC employee’s inventions and discoveries. Unless otherwise agreed in a written agreement signed by a University official with delegated authority, the University shall own all right, title and interest in any Invention made by (1) any employee, (2) any non-employee using University facilities, equipment, materials or resources, and/or (3) anyone who receives funds provided by or administered by the University. As a condition to each inventor’s employment at University and/or use of University facilities, the inventor does hereby assign any and all such Inventions to the University.

Foreign Influence

The U.S. Government has raised concerns about foreign threats to the integrity of research at national academic and research institutions. The concerns revolve around three main areas:

  • Diversion of intellectual property to foreign entities
  • Disclosing confidential grant application information by NIH peer reviewers to third parties
  • Failure of researchers to disclose research resources and support provided by other organizations, including foreign entities

Federal funding agencies have advised that there will be a heightened focus on ensuring compliance with respect to mandatory reporting of all sources of research support, financial interests and relevant affiliations, as well as steps to reduce risk to IP security. For EPAPs involving foreign entities, the faculty needs to talk to his/her departmental grants administrator to ensure he/she is meeting the new federal disclosure requirements.

For more information can be found on the UNC Research website.