Exemptions & Monitoring Plans

Exemptions to Florida Statute 112.313

Florida Statute 112.313 prohibits a University employee from having a contractual, employment, or financial relationship with a company that does business with the University.  The statute permits exemptions for transactions related to sponsored research and technology transfer upon full disclosure and approval by authorized University officials (President and the Board of Trustees Chair). A monitoring plan to mitigate the conflict of interest presented by the relationship will also be required.

Note: Without an approved Exemption, an employee cannot accept sponsored research awards or enter into an option/license agreement between UCF and a company with which they have a contractual, employment, or financial relationship.

Monitoring Plans

Once a potential conflict of interest is identified, the University must take steps to mitigate and monitor such conflicts.  A Monitoring Plan is a written document that clearly describes the nature of the conflict and outlines a plan to proactively address questions that may arise regarding the investigator’s objectivity, integrity, or professional commitment. UCF has created a standard monitoring plan to address conflicts of interest related to sponsored research. The standard monitoring plan can be tailored to address unique circumstances.

Implementing an Exemption and/or Monitoring Plan

Step 1: The employee must disclose the outside activity or financial interest on their online Potential Outside Activity, Employment, and Conflict of Interest and Commitment Disclosure (AA-21) form.

Step 2: The employee should complete the Conflict of Interest Exemption and/or Monitoring Plan (Sponsored Programs) form and upload it into the appropriate section of their AA-21.

Important Tip:  Our dynamic PDF forms may not be viewable in some web-based browsers. If you receive a “Please wait…” message when trying to open a form, please follow the below steps to access the file.

  1. Ensure Adobe Acrobat Reader is installed on your computer. Adobe Reader is a free application that can be downloaded at http://get.adobe.com/reader.
  2. Do not open the form within a web-based browser. Instead, download the file to your computer.
  3. From your computer, hover over the file with your mouse and right click on the file.
  4. A menu will display. Click on “Open with” and choose Adobe Reader.

Step 3: The Research Integrity & Compliance Office will review the form to ensure all the required information is provided and clear. The employee will be contacted if additional information is required.

Step 4: The Research Integrity & Compliance Office will schedule the case for review at the next Research Conflict of Interest Committee (RCOIC) meeting. The RCOIC will review the case, identify potential conflicts, determine if the conflict can be managed, and decide the conditions to be included in the Monitoring Plan.

Step 5: The Exemption and/or Monitoring Plan will then be routed for final approval by the Director of Compliance, Provost, President, and Chair of the Board of Trustees, as applicable.

Step 6: The approved Exemption and/or Monitoring Plan will be returned to the employee for final signature. The final plan will be uploaded into the employee’s Huron COI record.

Contact coi@ucf.edu if you have questions or need assistance with an Exemption and/or Monitoring Plan submission.

Annual Updates

Employees with a Monitoring Plan are required to submit an Update to Conflict of Interest Monitoring Plan (Form MP-1A) each year the plan is in effect. The form should be submitted with his/her AA-21 annual disclosure through the Huron COI reporting system.  (See above Important Tip if you receive a “Please wait…” message when trying to access the form).