Vanderbilt University Medical Center Finance

Conflict Disclosure System

What Is A Conflict.....

A "conflict of interest" normally refers to situations where the external interests of an employee have the potential to influence decisions in their job. If the influence could lead to personal gain (financial or non-financial) for the individual or their immediate family members, it must be disclosed.

Remember....

  • It is your responsibility as a Vanderbilt employee to disclose any conflicts that arise during your employment.These conflicts should be disclosed in the Conflict of Interest System.
  • At a minimum, the disclosure process must be completed by all staff each fiscal year.
  • Vanderbilt's fiscal year begins July 1st and ends June 30th.
  • It is expected that as an employee your main focus is to carry out the duties of your job without compromising your ability to serve Vanderbilt.
  • Be proactive and disclose any possible conflict as your circumstances change throughout the year.

Table of Contents

5 Most Common Conflicts
Creating A Disclosure
Resources

5 Most Common Conflicts

Second Job

Employees with a second job may have a conflict of commitment, and such outside employment should be reported on an employee’s disclosure. Commonly a management plan is developed that requires employees not to use Vanderbilt time or resources for outside activities, and the employee’s job performance is evaluated periodically to determine any time commitment issues related to his outside activities.

Consulting / Speaking

Consulting or speaking where healthcare industry sponsors are involved is highly regulated, and the Vanderbilt University conflict of interest policy should be consulted before undertaking. All consulting or speaking positions should be reported on the conflict of interest disclosure.

Gifts

No gifts of any amount may be accepted from healthcare vendors. Individuals may accept gifts, meals, entertainment and other normal social amenities no greater in value than $300 per year from a single source, whether an individual or a business, provided that the vendor is not a healthcare vendor and such amenities are not otherwise extravagant under the circumstances.

Family Working Together

Members of the Vanderbilt community may not participate in the hiring process or any employment-related decisions pertaining to their family members. Likewise, they may not be in a position to supervise a family member as an employee of Vanderbilt or otherwise review or participate in reviewing a family member’s work as an employee of Vanderbilt.

Family Business with Vanderbilt

Members of the Vanderbilt community may not review, approve, or administratively control contracts or business relationships when the contract or business relationship is between Vanderbilt and a business in which the individual or a family member has a financial interest or when the individual or a family member is an employee of the business and is directly involved with activities pertaining to Vanderbilt.


Creating A Disclosure

Adding a Disclosure

  1. Go to the COI website.
  2. Sign In.
  3. Read the instructions and select "yes" or "no" for each question.
  4. Read the 3 acknowledgements and check the appropriate box by each one.
  5. Click the lower right hand button that says "Continue to Select Approver".
  6. Select the approver.
  7. "Submit" your disclosure.

How to Select an Approver

  1. If the correct approver is listed, click continue.
  2. If someone other than your correct approver is listed, click on the word “here” in the sentence stating , “If this is not correct, click here.” This will allow you to type in your approvers last name, and to select your approver from a list of possible approvers.
  3. If no approver is preselected, click to continue to select your approver, and type in your approver’s last name. Select your approver, and click to continue.

Resources

VUMC COI Policy

VUMC COI Policy

Healthcare Vendor

Healthcare Vendor List