State and Local Government Conflict of Interests (COI) Act Compliance
The Commonwealth of Virginia requires the University to designate Members of the Board of Visitors and certain officers and employees of the University to file an annual financial disclosure document and to periodically complete the State and Local Conflict of Interests (COI) Act orientation course. Both are requirements of the State and Local Government Conflict of Interests Act (Title 2.2, Chapter 31 of the Code of Virginia) and the Governor’s Executive Order 16 (2010). These requirements reflect the Commonwealth’s continuing commitment that the judgment of public officers and employees will not be compromised or affected by inappropriate conflicts between personal economic interests and the official duties of Virginia’s public servants. State-wide, approximately 25,000 Virginia governmental officers and employees are required to disclose their financial interests each year (approximately 650 at the University).
University’s Conflict of Interests (COI) List
A list of these designated individuals is maintained and updated annually. Individuals are selected to this list based on the criteria found in the COI Act (§2.2 - 3114) and the Governor’s Executive Order 16 (2010) sections (2. a. and b). The President and each Vice President are responsible for approving additions and deletions to the COI list. The University’s COI List includes:
Members of the Board of Visitors
All officers and employees included on the University’s Organization Chart (with the exception of “Executive Assistants to”)
Employees that have substantive responsibility for finance, procurement, audit, investment, contract compliance, inspection, investigation, project management, human resources, and legal services (this list is not all inclusive)
Faculty researchers that have received an approved waiver from the President for a research conflict. Research conflict waivers are reported to the Board of Visitors.
Officers and/or employees that have received an approved waiver from the President for a procurement conflict.
Board Members remain on the University’s COI list until their appointment expires. Officers and employees remain on the list until they terminate employment, no longer require a President’s waiver for a conflict, or their duties and responsibilities for being selected significantly change.
The COI Act requires financial disclosure documents to be filed by January 15th of each year. It is the responsibility of the Secretary of the Commonwealth (SOC) to manage the collection and recordkeeping of these documents. To improve filing and recordkeeping, the SOC introduced a new online filing system for the January, 2013 filing. The new system is called the Conflict of Interest Disclosure System and ends the filing of paper documents and the need to have a filer’s statement notarized by a Notary Public. Once the filer accesses the new system, the filer uses an online guide to walk them through the completion of their disclosure statement. The online form uses an electronic signature. The new system also retains copies of previous submissions.
The SOC’s website provides multiple financial disclosure documents. Board Members complete the “Financial Disclosure Statement”; designated officers and employees including Medical Center employees complete the “Statement of Economic Interests”. The Disclosure of “Real Estate Holdings” document is not applicable. There are FAQ’s on the SOC’s website providing guidance to complete these documents. There is also a User’s Guide for the Conflict of Interest Disclosure System.
Financial disclosure documents are subject to the Virginia Freedom of Information Act.
Notification of Financial Disclosure Filing
The COI Act requires that Board Members and designated officers and employees receive notice of their annual COI Act requirement on or before November 30th of each year. An email notice will be sent directly from the Conflict of Interest Disclosure System from - (yy EadPortalGovCoi ConflictofInterest@governor.virginia.gov).
The email notification will include:
- Deadline for filing
- Link to the Conflict of Interest Disclosure System.
Once logged into the system, go to “My Disclosures” and select the indicated financial disclosure form. This will take you to the online guide for completing your financial disclosure.
- Deadline for filing
- Link to the Conflict of Interest Disclosure System
- Second email that provides instructions for registering (includes a link and pin number to establish a new account)
Once logged into the system, go to “My Disclosures” and select the indicated disclosure form. This will take you to the online guide for completing your financial disclosure.
The COI Act’s deadline is normally January 15th unless the day falls on a Saturday, Sunday, or legal holiday. If this is the case, the date is changed to the first workday following Sunday or the legal holiday.
Certain new employees may be requested to file a Statement of Economic Interests and complete the State and Local Conflict of Interests (COI) Act orientation course shortly after their arrival at the University. These individuals will be contacted by the COI Coordinator. Instructions for using the Conflict of Interests Disclosure System and accessing the COI training course will be provided. These employees are also required to file the annual disclosure. Research Faculty seeking a waiver from the President for a research conflict must also file a Statement of Economic Interests and complete the COI Training course at the time of their waiver request.
REMINDER: Filing the Statement of Economic Interests does not relieve you of your obligation to comply with other requirements of the State and Local Government Conflict of Interests Act.
Late Filing of Required Financial Disclosure Documents
All officers and employees missing the COI Act’s deadline will be reported to their respective Vice President, the Executive Vice President and Chief Operating Officer, and the Vice President and Chief Human Resources Officer.
Any person who does not file or who knowingly files the Statement of Economic Interests form inaccurately may be subject to criminal and/or civil penalties. Any person who knowingly files the form inaccurately may also be dismissed from office or employment.
Please contact the COI Coordinator if you have a compelling reason for filing late such as a death in the family, being on leave for health reasons, not receiving required financial information from a third party, and the like. The COI Coordinator will contact the Office of the Secretary of the Commonwealth and request an appropriate extension on your behalf. Approval of all extension requests are at the discretion of the Office of the Secretary of the Commonwealth.
State and Local Conflict of Interests (COI) Act Training
The State and Local Conflict of Interests (COI) Act orientation course (COI Training) was developed by the Office of the Attorney General. COI Training is available online through the University’s Integrated System. The training must be completed within 60 days of becoming a state filer and at least once during each consecutive period of two years commencing on the first odd-numbered year thereafter. COI Training covers the Conflict of Interests Act and the ethics portion of the Virginia Procurement Act. The training takes approximately one hour to complete.
Notification to Complete the State and Local Conflict of Interests (COI) Act Orientation Course (COI Training)
The COI Coordinator will notify Board Members and designated officers and employees by email when the COI Act Training must be completed. The COI Coordinator is responsible for keeping a public record of completion dates of all individuals subject to the COI Act. Tracking completion dates is necessary since the COI Training is required every other year. For employees, the COI Training course is available through the University’s Integrated System (Oracle Learning Management System). Board Members will be provided a direct link to the COI Training course.
Accessing COI Training through the University’s Integrated System
For employees the COI Training notification email will provide an access link directly to the login page of the University’s Integrated System and to the Virginia State and Local Conflict of Interests (COI) Act Training:
- Integrated System login window appears; please enter your login id and password (assistance with both login id and password may be obtained through the HR Service Center at 982-0123)
Course window - Virginia State and Local Conflict of Interests (COI) Training will appear; select this link (Proceed to step 3. below)
Note: You may also access the COI Training by logging into the Integrated System; select UVA Employee Self-Service; within the UVA Employee Self-Service options select Learning; select Learner Home; enter COI in the keyword search box; select Go; Course window - Virginia State and Local Conflict of Interests (COI) Training will appear; select this link (Proceed to step 3 below).
Classes window appears; select ”Enroll” (far right of screen)
- Class Summary window appears; select “Apply” (far right of screen)
- Enrollment window appears; select the “Play Button” adjacent to the Virginia State and Local Conflict of Interests (COI) Act Training (in the Play column) to launch the COI Training
- Complete the training
Note: You do not need to complete the COI Training in one session. Once you select Play and the COI Training opens, you will receive a prompt asking you if you wish to commence the training where you left off (select yes), or to start the training at the beginning (select no).
To verify your successful completion, it is important to do the following when closing the COI Training.
- Select exit just above the top right of the training screen
- A window opens, select Exit Now
- On the next screen, select the Learner Home icon (small house) top right of the screen
- On your Learner Home screen you should see “Completed” in the Status column adjacent to the Virginia State and Local Conflict of Interests (COI) Act Training.
Please do not send any communication or documentation regarding completing the course to University Human Resources, the Integrated System has created a record of your completion.
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