State and Local Government Conflict of Interests (COI) Act Compliance

Financial Disclosure

The Commonwealth of Virginia requires Members of the University’s Board of Visitors and certain officers and employees of the University to file an annual financial disclosure document. 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) 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).

The State and Local Government Conflict of Interests Act (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. Documents are to be collected at the agency level before being submitted to the SOC’s Office to meet the January 15th deadline. Financial disclosure documents are subject to the Virginia Freedom of Information Act.

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.

The SOC’s website provides financial disclosure documents. Board Members complete the Financial Disclosure Statement; University 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.

Further instructions for completing the Statement of Economic Interests are indicated below.

State and Local Conflict of Interests (COI) Act Training

The COI Act further requires all Board Members and University officers and employees to successfully pass the State and Local Conflict of Interests (COI) Act Training (COI Training). The content of the COI Training was developed by the Office of the Attorney General. The online COI Training is available through the University's Oracle Learning Management 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. Instructions for accessing the University's Oracle Learning Management system and online COI training are indicated below.

University’s Conflict of Interests (COI) List

The University maintains a list of individuals required to complete the Commonwealth of Virginia’s Conflict of Interests requirements. Individuals are selected to this list based on the criteria found in the COI Act (Title 2.2, §§3104 and 3110.5) 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”)
• Certain 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.

Timetable for Submission of Financial Disclosure Documents

Board Members, officers, and employees will receive notice of their annual COI requirement by email prior to November 30th of each year from the University’s COI Coordinator.

Notification will include:

• Required financial disclosure document to be completed
• University’s deadline for submission [Secretary of the Commonwealth (SOC) requires the University to collect documents]
• Need to complete the COI Training.

The required financial disclosure document must be completed and submitted to University Human Resources by the University’s deadline which is usually four or five days prior to the COI Act’s deadline. If required, the COI Training must be completed by the University's deadline. The COI's deadline is 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.

Instructions for Completing the Statement of Economic Interests

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.

Please read the “Instructions” on page 1 of the Statement of Economic Interests booklet and the “Definitions and Explanatory Material” on pages 2 and 3. Refer to the FAQ’s on the SOC’s website.

• For the question “Candidate for Election to this office?” answer “No”.
• For the question “Office or Position Held or Sought” provide your “Work Title”.
• Complete the ten (10) “Yes” or “No” questions (you must answer all ten).
• Complete the corresponding “Schedule” if you respond “Yes” to any question.

Tips:

• Question 1 – refers to outside businesses not your University position.
• Question 2 – contingent liability is a future liability such as a parent guarantying a car loan to a son or daughter.
• Question 3 – includes TIAA-CRE and Fidelity retirement accounts.
• Question 4 – states “in your capacity as an officer or employee of your agency” (not your private consulting).
• Question 5 – includes the University.
• Question 6 – exclude University salaries. Be certain to check the box if there are no reportable salary or wages.
• Question 7 – self explanatory.
• Question 8 – respond Yes/No to all three questions (8A, 8B, and 8C).
• Question 9 – complete only 9A (9B – Local Officers and Employees refers to city and county governmental employees.
• Question 10 – only if with a governmental agency.

Your completed Statement of Economic Interests must be notarized to be accepted (several notaries are available at University Human Resources). Attach all required Schedules to your statement in alpha order. By the University deadline, submit your completed and notarized statement and required Schedule(s) by messenger mail or the U.S. Mail to:

COI Coordinator
University Human Resources
914 Emmet Street
P.O. Box 400127
South Michie Building
Charlottesville, VA 22904-4127

Note: Your statement may also be hand-delivered to the Receptionist in the Front Lobby of the Michie South building.

Late Filing of Required Financial Disclosure Documents

All officers and employees missing the University’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. The Office of the Secretary of the Commonwealth requires that a list of delinquent filers be submitted with the University’s financial disclosure documents.

Any person who does not file or who knowingly files the Statement of Economic Interests form inaccurately may be charged with a Class 1 Misdemeanor which is punishable by no more than 12 months in jail and a fine of no more than $2,500. 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, being out of the country, 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 (SOC) and request an appropriate extension on your behalf. Approval of all extension requests are at the discretion of the SOC’s Office.

Instructions for Completing the State and Local Conflict of Interests (COI) Act Training

The COI Training course is available through the University’s Oracle Learning Management system for employees of the University. Board Members will be provided a separate link to the COI Training course. The COI course consists of five modules covering the Conflict of Interests Act and the Ethics portion of the Virginia Procurement Act. The course takes approximately 1 hour to complete.

To access the COI Training course (for employees):

• Log into the University’s integrated system and select “UVA Employee Self-Service”
• Scroll down the menu and select “Learning”
• Select “Learner Home”

Note: All employees required to take the COI Training course will be pre-enrolled for the training (once Learner Home is opened the COI course will appear). One may also search for the COI Training by selecting “Course” and entering COI in the search window and then selecting the “Go” button.

• Select the button in the “Play” column to open the navigation page
• Read and print (Ctrl P) the instructions for navigating between modules and exiting the COI Training Course
• Select “Module 1” (select “Yes” in the Resume Presentation window) to start the narrated presentation; complete Module 1

Note: All slides in each module must be viewed and the quiz questions answered correctly for each module to be successfully completed. Select “Finish” once you see the Quiz Results screen.

Important:

• To access Module 2 close out the entire window (X at the top right of your screen) to return to the navigation page to select Module 2 (follow the same procedure to complete Modules 3 through 5)
• To exit the COI course (and the integrated system) at any point select File > Exit from the menu (top left of your screen); you will see a small screen indicating “Saving data. Do not close this window”; please close this window.

Note: To return to the COI course follow the same instructions starting above with the bullet “Log into the integrated system and select UVA Employee Self-Service”. If you stop before completing a module, select that module again from the navigation page (select “Yes” in the Resume Presentation window to start at the point you left off or “No” to start the module from the beginning).

Note: Do not follow the instructions on the last screen (Congratulations screen) of each module for navigating to the next module or exiting the course. The EXIT button right of the ATTACHMENTS button on the Congratulations screen is disabled.)

Once you have completed all five modules of the COI Training course, you do not need to send any communication or documentation to University Human Resources. You may verify that you have completed the course by logging into the integrated system and selecting “UVA Employee Self-Service”, “Learning”, and “Learner Home”. The COI Training course will appear and you should see in the “Status” column (second column) “Completed”. After completing the course, you may click the button in the “Move to History” column to move your enrollment record to your Learning History page.

Contact information:

David W. Ripley
University COI Coordinator, University Human Resources
914 Emmet Street, South Michie Building
P.O. Box 9004127

Phone 434.924.4373 fax 434.924.3194
dwr@virginia.edu

Role of Conflict of Interests (COI) Coordinator

Responsibilities include:

• Updating the University’s COI List
• Obtaining approval from each Vice President for the officers and employees listed within their respective organizations
• Submitting a preliminary University COI List to the Office of the Secretary of the Commonwealth (SOC)
• Notifying Board Members, officers and employees of the annual filing, the financial disclosure document to use, the need to complete the COI Training, and the University deadline for the submission of documents
• Collecting and acknowledging all financial disclosure documents
• Checking and verifying that financial disclosure documents are complete (all ten questions are answered, appropriate Schedule(s) are attached, documents are signed and notarized)
• Sending status reports of individual compliance to each Vice President
• Submitting all University financial disclosure documents to the SOC
• Notifying the SOC of delinquent filers
• Requesting extensions for late filers
• Obtaining financial disclosure documents from late filers and sending them to SOC
• Tracking and acknowledging successful completion of the COI Training
• Updating the COI Training roster for public inspection
• Answering procedural questions