University of Pittsburgh supervisors are responsible for reviewing and approving disclosures submitted by their supervisees. Learn about the financial, personal, and professional interests, activities, and relationships that must be disclosed. Supervisors complete a formal review and approval of the disclosures in MyDisclosures and are responsible for identifying potential Conflicts of Commitment (COC) and Conflicts of Interest (COI).
Following is an overview of the supervisor review and approval process in MyDisclosures as well as guidance for supervisors regarding how to identify potential COCs and COIs.
Pitt employees who are also employed by UPMC complete a single Annual Disclosure in MyDisclosures. These individuals must also follow UPMC policies on COC and COI, which are reviewed by their UPMC supervisors under a separate process outside of MyDisclosures. Questions regarding UPMC policies and supervisor reviews should be emailed to conflicts@upmc.edu.
MyDisclosures
Primary Supervisor
When a Pitt employee completes their Annual Disclosure in MyDisclosures, they identify their Pitt primary supervisor. Faculty usually identify their department chair or division chief, and staff usually identify the individual who completes their annual performance reviews.
Secondary Supervisor
A Pitt employee may also have a secondary supervisor, who they can identify in MyDisclosures. For example, faculty may report to their department chair and to the director of a Pitt institute.
Supervisor Review and Approval
An Annual Disclosure that is pending supervisor review and approval will be in a Department Review or No Interests Disclosed state. The Department Review state indicates the Pitt employee disclosed outside interests, activities or relationships. The No Interests Disclosed state indicates the Pitt employee did not disclose any outside interests, activities or relationships.
When a Pitt employee disclosed any outside interests, activities or relationships and identified a secondary supervisor, the secondary supervisor review is required. The secondary supervisor must complete their review before the primary supervisor and should share any concerns with the primary supervisor.
When a Pitt employee did not disclose outside interests, activities or relationships and identified a secondary supervisor, the secondary supervisor can view the disclosures, but their review is not required.
All supervisors, whether primary or secondary, will receive email notifications from MyDisclosures when there are disclosures pending their review. To review and approve disclosures, supervisors should log into MyDisclosures and select the Supervisor Center link.
After an Annual Disclosure has been reviewed and approved, the state will change to Review Complete.
Training and Guides
MyDisclosures training videos and user guides are available on the COI website:
Additionally, the COI Division is available to provide in-person training or to discuss questions. Please email coi@pitt.edu to request a training or meeting.
Conflicts of Commitment
A COC exists when a Pitt employee has outside activities that interfere with their willingness or ability to perform their institutional responsibilities. While outside activities may promote professional development that benefits Pitt, they create COCs when, for example, the time spent on these activities interferes with their performance of their Pitt responsibilities.
Time Spent on Outside Activities
Full-time faculty are permitted to use an average of one day per week of their Pitt time on outside activities. They may spend additional time during weekends and evenings, which are not counted in this limit. Review additional information.
Staff must ensure all time spent on outside activities is done outside of their Pitt work hours.
Academic Activities
If a Pitt employee discloses academic activities that occur outside of Pitt but are part of their Pitt responsibilities, these activities do not usually create a COC. Examples include:
- Presenting scholarly work or giving lectures at U.S. universities;
- Preparing or reviewing books, articles, works of art or artistic performances expected in the normal course of Pitt institutional responsibilities;
- Editing academic publications;
- Serving on committees or governing boards of professional groups; and
- Serving on U.S. government advisory groups, study sections or advisory panels.
Pitt Resources
Pitt resources may not be used for outside activities. This includes Pitt facilities (e.g., lab space and offices), other Pitt employees, students, and equipment.
However, incidental use of Pitt resources may be permitted. Incidental use is limited personal use of Pitt equipment or services that Pitt is already providing. There must be no additional expense to Pitt, the use may result in only normal wear and tear, and the use must comply with existing contractual obligations.
An example of incidental use that supervisors generally approve is when a Pitt faculty member consults for a company and uses their Pitt-provided laptop to access their personal email to communicate with the company.
Foreign Institution of Higher Education or Foreign Government
When a Pitt employee discloses an outside activity involving a foreign institution of higher education or foreign government in MyDisclosures, they may also be required to disclose these outside activities to their funding agency as other support. The Office of Sponsored Programs provides links to agency-specific information. Outside activity involving a foreign institution of higher education or foreign government may also require a review by the Office of Research Security & Trade Compliance.
Foreign Talent Recruitment Program
It is important to distinguish between foreign talent recruitment programs that follow U.S. research integrity principles and those that do not. The Office of Research Security & Trade Compliance provides information on foreign talent programs and is available to address questions by email at researchsecurity@pitt.edu.
COC Management
Most of the time, outside activities do not create COCs. However, when a supervisor determines that a Pitt employee has outside activities that interfere with the employee’s willingness or ability to perform their institutional responsibilities, or exceed time allowable by policy, a potential COC exists.
When a supervisor identifies a potential COC, they are encouraged to discuss their concerns directly with the supervisee. Additionally, the supervisor can reach out to the Conflict of Interest (COI) Division. While supervisors are responsible for reviewing and managing COCs, the COI Division serves as a resource and can answer questions and provide guidance. Email the COI Division at coi@pitt.edu with questions or to request a private meeting.
Following are examples of strategies a supervisor may implement to manage a potential COC:
- Prohibit engagement in an outside activity that is detrimental to the department/office or to Pitt
- Limit time spent on outside activities to ensure their standards of performance at Pitt are being met and policy requirements are met
- Require the Pitt employee to disclose their COC to faculty, staff or students who may be affected
- Refer potential COCs that also involve COIs to the COI Division
Conflicts of Interest
A potential COI exists when faculty or investigators have significant financial interests that relate to their Pitt research or other activities. While a COC focuses on the willingness or ability of a Pitt employee to perform their institutional responsibilities, a COI focuses on the potential for outside activities that include significant financial interests to bias Pitt research or other activities.
COI Identification, Review, and Management
The COI Division collaborates with colleagues from other Pitt offices to identify potential COIs and facilitates their review and management. For some potential COIs, review and management by the Conflict of Interest Committee or Institutional Conflict of Interest Committee is required. When a conflict management plan (CMP) is executed for a COI, the CMP is shared with the individual’s supervisor.
Additional information regarding COIs and CMPs is available on the COI Division website.
Supervisor Identification of COIs
While meeting with Pitt employees or reviewing and approving Annual Disclosures, a supervisor may identify a potential COI that has not been reviewed and, if necessary, managed. Following are a couple examples:
- A Pitt employee disclosed that they created a new start-up company, and the supervisor is concerned that results of the employee’s Pitt research could affect the value of that company
- A Pitt employee discusses an opportunity to consult for a company with their supervisor, and that company also sponsors the employee’s Pitt research
If a supervisor has concerns regarding potential COIs, they should contact the COI Division to determine whether there is a COI that requires a CMP. The COI Division is available by email at coi@pitt.edu or in MyDisclosures by clicking the “Request Assistance from the COI Office” link included in the Pitt employee’s Annual Disclosure.
Questions to Consider
Supervisors should consider the following questions when determining if their supervisee’s outside activities are compliant with Pitt policies and whether they create a potential COC or COI.
- Compliance with Pitt policies:
- Did they obtain your approval prior to beginning the outside activity?
- Are they using Pitt resources to perform the outside activity?
- Does the outside activity involve a foreign institution of higher education or foreign government?
- Does the outside activity involve participation in a foreign talent recruitment program?
- Create a potential COC :
- Are they meeting all expected standards of performance?
- Are they adequately fulfilling their Pitt responsibilities?
- Is the time spent on outside activities appropriate?
- Will their engagement in the outside activity be detrimental to their department/office or to Pitt?
- Does their outside activity interfere with their personal objectivity in teaching, research or other Pitt responsibilities?
- Create a potential COI:
- Does their outside activity, financial interest or relationship bias or have the potential to bias their personal objectivity in teaching, research or other Pitt responsibilities?
- Did they previously disclose their outside activity, financial interest, or relationship? Are there any changes from the previous disclosure?
- Did the COI Division complete a review and implement a CMP? If you are not sure, email coi@pitt.edu.