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. University Board of Visitor Members are also required to file and complete the training. 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 number 33. 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 700 at the University).

University’s Conflict of Interests (COI) List

A list of these designated individuals is maintained and updated semiannually. Individuals are selected to this list based on the criteria found in the COI Act (§2.2 - 3114) and the Governor’s Executive Order. 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 having 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 having an approved waiver from the President for a research conflict. Research conflict waivers are reported to the Board of Visitors.

  • Officers and/or employees having 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 or no longer require a President’s waiver for a conflict. Officers and employees may also be dropped from the University’s COI List if their assigned duties and responsibilities no longer meet the criteria for being a designated employee.

Financial Disclosure

The COI Act requires financial disclosure documents to be filed semiannually each year. The State filing deadlines are June 15th and December 15th. It is the responsibility of the Secretary of the Commonwealth (SOC) to manage the collection and recordkeeping of these documents. An online filing system (the Conflict of Interest Disclosure System) is used to file disclosures. The System provides assistance to filers in the completion of their disclosure statement. Filers sign their completed disclosures electronically. The System also retains a copy of the filers’ previous disclosure to assist in completing future disclosures.

The June 15th filing deadline covers the reporting period of November 1st of the preceding calendar year through April 30th; the December 15th filing deadline covers the reporting period of May 1st through October 31st. The SOC expects an employee to file a new financial disclosure if they work any time during these reporting periods. As an example, an employee terminating on June 1st is required to file a new Statement of Economic Interests (financial disclosure) for the May 1st through October 31st reporting period. This filing may be completed at the time of termination, but no later than December 15th of the calendar year of the employee’s termination.

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.

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.

Notification of Financial Disclosure Filing

University Board Members and designated officers and employees receive notice of their semiannual COI Act requirement from the online Conflict of Interest Disclosure System and the University’s Conflict of Interests Coordinator. The University’s Conflict of Interests Coordinator (COI Coordinator) will initiate this notice after receiving guidance from the SOC. The System email notice will be sent from - (ConflictofInterest@governor.virginia.gov).

The email notification will include:

Previous users:

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.

New users:

  • Deadline for filing
  • Instructions for registering are provided in a second email (includes a link and pin number to establish a new account).
  • Link to the Conflict of Interest Disclosure System.

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.

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 next semiannual 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.

Late Filing of Required Financial Disclosure Documents

All officers and employees missing the COI Act’s deadlines 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. 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 development and revision of the State and Local Conflict of Interests (COI) Act orientation course (COI Training) is the responsibility of the Office of the Attorney General. 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. Board Members initially complete the COI Training as part of their appointment process. Once appointed, Board Members receive a direct link to the COI Training. For Officers and employees the COI Training is available online through the University’s Integrated System. 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)

University Board Members and designated officers and employees receive email notice to complete the required COI Training directly from the COI Coordinator. This notification is separate from the Conflict of Interest Disclosure System’s filing notification. COI Training is to be completed by December 15th of the calendar year required. As a result of the COI Training being required every other year, the COI Coordinator is responsible for tracking which designated employees are required to file each year. Close to half of the University’s designated employees are required to complete the COI Training each calendar year.

Failure to Complete the COI Training

The COI Coordinator is responsible for keeping a public record of completion dates of all individuals completing the COI Training. Individuals failing to complete the COI Training 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.

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:

  1. 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)
  2. 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).

  3. Classes window appears; select ”Enroll” (far right of screen)

  4. Class Summary window appears; select “Apply” (far right of screen)
  5. 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
  6. 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.

Other Conflict of Interest (COI) Laws or Policies Applicable to University Faculty or Staff

In addition to the State’s COI semiannual filing and training requirement, there are other “Conflict of Interest” requirements under federal and state law or University policy that affect University Faculty and Staff. Several different University organizations administer/coordinate these COI requirements. University Human Resources is responsible for the coordination of the State of Virginia’s Conflict of Interests mandated by the State and Local Government Conflict of Interests Act. The Act requires certain University employees based on the level and type of their assigned job duties to be “designated” by the University to comply with the Act’s requirements. Members of the University Board of Visitors are also required to comply. Under the Act, both employees and BOV are required to file a semiannual financial disclosure form and complete training on the Conflict of Interests Act and the Ethics in Public Contracting portion of the Virginia Public Procurement Act (COI Training).

The Department of Procurement and Supplier Diversity Services has Conflict of Interests responsibility mandated by [Section 2.2-3110 of the State and local Government Conflict of Interests Act] (https://leg1.state.va.us/cgi-bin/legp504.exe?000+cod+2.2-3110) . The Act authorizes public institutions of higher education to contract with a firm in which a University employee or a member of his/her immediate family owns equity as long as the University and employee meet certain obligations designed to maintain and promote confidence in public contracting. These obligations include, but are not limited to, employees disclosing in writing their interest(s) in a firm seeking to enter into a contract with the University, and confirming that they will not participate in any part of the contract negotiation process. In addition, the President must also certify that the negotiated contract is in the best interest of the University. This process starts with a July email to all University employees requesting that they self-report any interest(s) in a firm that is contracting or plans to contract with the University. If an employee self-reports ownership in a firm and the University’s contract with the firm reaches a certain dollar threshold, the employee is required to file the State’s financial disclosure form and complete the COI training. For more information contact Eric Denby, end@virginia.edu or (434) 924-4019.

The Office of the Vice President for Research is responsible for a Conflict of Interests process under University Policy, “Financial Conflicts of Interests for Research Investigators”, RES-005 . Research Investigators must comply with both Federal and State Conflict of Interests requirements to ensure a reasonable expectation that their design, conduct, and reporting of research will be unbiased by any conflicting financial interest(s). They must comply with the Federal Department of Health and Human Services regulations on “Promoting Objectivity in Research” – 42 CFR Part 50, Subpart F, and 45 CFR 94. They may also need to comply with the requirements of other federal agencies (e.g., Department of Defense, National Science Foundation, and the like). Research Investigators further must comply with the Virginia State and Local Conflict of Interests Act. They must disclose their “personal Interests” prior to the negotiation of the contract with the University, Section 2.2-3106 . This includes completing the State of Virginia’s financial disclosure form prior to the University President approving the exception. University Human Resources assists the Office of the Vice President for Research by coordinating the investigator’s completion of the State’s COI requirement. In some cases, research investigators may also need to self-report their “personal interests” through Procurement and Supplier Diversity Services. Once the Research Investigator has been granted an exception (Waiver from the President), the University designates the investigator to comply with the State’s COI requirement of filing a financial disclosure form and completing the COI training. For more information contact Dave Hudson, djh2t@virginia.edu or (434) 243-0900.

The School of Medicine’s (SOM) Policy on Conflict of Interest and Conflict of Commitment, Policy ID:2.001 requires all School of Medicine Faculty and Investigators to disclose annually all financial interests that relate to institutional responsibilities using the SOM online disclosure system. Any new financial interests must be disclosed within 30 day. Recently hired SOM faculty must disclose their financial interests within 30 days of their initial appointment. This process is totally separate from Virginia’s Conflict of Interest requirements. For more information contact Steven Wasserman, ssw3an@virginia.edu or (434)243-7088.

Other Conflict of Interest Policies:

Faculty Conflict of Interest Policy

University Conflict of Interest Policy

Contact information:

Compliance and Immigration Services

University Human Resources

914 Emmet Street, South Michie Building

P.O. Box 9004127

immigration@virginia.edu