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CONFLICT OF INTEREST REQUIREMENT FOR ALL EMPLOYEES
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UPDATE REQUIRED BY MAY 31, 2008
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The
NSF GPM Policy 510 requires that non-profit institutions employing more
than 50
individuals receiving federal funding maintain a written and enforced
policy on
conflict of interest that includes financial disclosures, institutional
review
of disclosures, the resolution of any problems dealing with conflict of
interest, and an enforcement mechanism. Effective immediately all
exempt
Observatory Staff as defined in the COI policy are required to:
- File a conflict of
interest screening form annually. This form must be filed before a
proposal can be submitted or funds expended.
- File a revised conflict
of interest form whenever a new transaction or activity is proposed
that might involve a conflict of interest.
- Contact the conflict of interest
officer (KAREN WILSON) whenever there is a change in
interests that might pose a conflict of interest.
Conflict of
Interest Policy
Conflict
of Interest Form (Attachment A)
Conflict of Interest Update Web-Form
Up-to-date information, the conflict of interest screening/disclosure
form and contact numbers for additional information, may be obtained
through the NOAO Office of Sponsored Projects.
FAQ'S
1. If I just completed a form do I need to complete
it again this May?
Yes,
we will be updating through the new web-questionnaire system annually each
May. This
will put everyone on the same time frame and allow for a clean data base.
This can be found at: http://www.noao.edu/cfo/CAS/casupdate.php
2. Am I completing a full disclosure form
annually?
Only
if you have changes since your last submission. HOWEVER
you must complete the short web-questionnaire annually certifying your status
since the last submission. A shorter process than the first form.
If you
have changes since the last submission, you will need to complete a new form
with the updates. (The web-questionnaire does not accpet changes.) The form can be found online at http://www.noao.edu/cas/hr/COI/COI-AttachmentA.pdf
3. What if I have never filled out a COI
Form?
You will need to complete the Conflict of Interest
Form first and then you will be able
to use the short status form annually if there are no changes.
A form may be found at
http://www.noao.edu/cas/hr/COI/COI-AttachmentA.pdf
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