Frequently Asked QuestionsWhat is the intent of the University's CERT Program?
This program was developed to assist employees and the
University in meeting legal and ethical standards. It is critical that
all dealings be handled with the highest of standards as a way to assure the
public we serve that we are managing our resources in a way reflects positively
on us as university and community citizens. As such, the
integrity of all university work and service, including teaching, research,
scholarly activity, and business or financial matters, must not be
compromised. How often do I need to complete the e-CERT (Employee Conflict of Interest Disclosure)?
How do I report a potential conflict of interest?
A conflict of interest disclosure is required upon:
- Within 30 days of being newly hired at the university
annually for all faculty and staff
- When circumstances for an employee changes (such as a
relationship) where the disclosure needs to be updated for accuracy
Why do I need to include information on family members?
should go to the e-CERT to enter or update this information. This
is located at: http://tinyurl.com/NAU-CERT
. This is an automated tool that will walk you through the
employee disclosure that is required. You may also want to talk with your
supervisor or someone in your management reporting chain about this conflict or
contact one of the key resource offices listed on the main page of this
Why do I need to complete this e-CERT disclosure?
Close relationships (such as relatives or domestic
partnerships) with other NAU employees or students have the potential to create
situations in your work or service where the best interest of the University
may conflict with (or be perceived to conflict) with your personal
interests. Therefore it is required that you disclose the required
information about these relationships so that a conflict management plan can be
implemented (if one is needed) or action taken to prevent such conflicts of
The federal and state regulations that govern objectivity in research require disclosure of financial interest including those of your spouse or domestic partner and/or dependent children.
The University is obligated by federal and state laws and regulation, to identify, manage, reduce, and if possible, eliminate any potential conflict of interest.Do all PI(s) and Co-PI(s) need to complete the e-CERT disclosure annually?
Yes. The PI, Co-PI(s) and all investigators must complete the e-CERT disclosure annually. The term investigator refers to any individual (including but not limited to employees and students) acting for or on behalf of the University, who is responsible for the design, conduct, or reporting of sponsored activities.When do I need to complete the e-CERT disclosure?
The e-CERT disclosure must be completed at the time of hire, when a potential conflict arises and annually.Do I have to report changes in my activity and/or interests before the next submission date?
Do students need to complete the e-CERT (Employee Disclosure)?
Any changes in the status of an existing conflict of interest disclosure should be disclosed immediately and a new online submission completed.
How do I determine if a financial interest requires reporting?
All employees, including student workers and graduate assistants for NAU must also complete the e-CERT disclosure. A student that has no employment or specific research role (as described below) should not complete the disclosure.
If a student’s role in the study includes being a PI, co-investigator, or other senior/key personnel then they must complete an e-CERT (disclosure). Individuals who are responsible for designing, conducting, or reporting on a sponsored project or a proposal are collectively referred to as Senior/Key Personnel or Investigators. This includes the Principal Investigator/Project Director or co-investigator/co-director on a particular proposal, and may include postdoctoral associates, senior scientist, graduate students, and collaborators or consultants depending on their roles.
The e-CERT (Employee Conflict of Interest disclosure) will
provide the details you need to determine whether your situation meets the
criteria for disclosing. Additionally, policies found on the CERT website
related to purchasing and research (if applicable to you) may also explain
these requirements. If you cannot find the information you need, please
go to the Key Resource Office link on the left menu bar of this site. What will happen if I fail to report or disclose a conflict of interest?
What is a conflict management plan?
As with any violation of University or Arizona Board of Regents policy or state statute, all employees are subject to disciplinary actions, up to and including termination for the most serious offenses. Some very specific penalties apply under Arizona statutes which pertain to purchasing, contracting, or receiving financial benefit as a result of one’s state employment. Knowingly violating some state conflict of interest laws are considered a class 6 felony. A listing of related policies and statutes can be found in the Related Policies
section of the CERT website.
What is a supervisor, chair, or other manager’s responsible for in the CERT program?
A conflict management plan may include any of the
- Avoiding certain types of activities. There will be
some circumstances when it is necessary for an employee of the university
to cease certain activities (external or internal) in order to reduce the
risk of conflict of interest in their NAU position.
- Minimize the risk of a potential conflict of interest
by establishing an arrangement that is agreed upon by the management
chain, key resources offices, and/or university counsel that helps the
institution avoid and/or properly manage the potential conflict.
- Disclosing certain relationships or outside interests
to NAU. In some cases additional actions may be required beyond
disclosure, but not always.
Conflict management plans should be discussed between the
employee with the real or potential conflict and their
supervisor/chair/manager. Discussion and agreements to manage or avoid
the conflict of interest or cease certain activities should be documented and
retained by the supervisor or a member of the management reporting chain.
The supervisor or manager should also monitor the situation to ensure that the
agreement is being followed. Conflict management plans may also need to
be shared with certain key offices (HR, Legal, Affirmative Action, Research)
depending on the nature of the situation.
Who do I call for more information?
- Completing an e-CERT for their employment situation in accordance with the requirements.
- Become knowledgeable about the program using the resources provided, tutorial, quiz, website, examples, FAQ’s, etc.
- Participating in discussions with their employees who reveal a real or potential conflict of interest. Assist employees in finding answers to their questions about how to comply.
- Discussion should include what to avoid, how to modify situations to avoid conflicts of interest, or whether another type of remedy is warranted.
- Contacting a key resource office (left menu bar of the CERT website) to discuss how to handle a situation disclosed by the employee if you are uncertain.
- Documenting the discussion and agreement of a specific conflict management plan. The documentation should include a date of discussion, names of parties to the discussion, how the conflict of interest (or potential of) will be managed, eliminated or avoided. Share a copy with the employee and retain a copy in the employee’s departmental file.
- Follow up or monitor situations that require a conflict management plan as appropriate. Bring issues of concern to another manager in your management reporting chain OR contact the appropriate key resource office for assistance.
- Report anything you are not comfortable with until you are satisfied that the situation has been handled correctly.
The offices listed in the top left menu on this page under "Key Resource Offices" can provide additional information on this topic.I work on a sponsored project. Do I have to complete the sponsored project disclosure?
Maybe. Consider your actual role on the project: Are you responsible for designing, conducting, or reporting on a sponsored project or a proposal? If so, the answer is YES.
Individuals with these responsibilities are collectively referred to as Senior/Key Personnel or Investigators, and include the Principal Investigator/Project Director or co-investigator/co-director on a particular proposal, and may include postdoctoral associates, senior scientists, graduate students, and collaborators or consultants depending on their roles.
If your job responsibilities do include those listed above, you will need to disclose your and your family’s significant financial interests. That disclosure allows the University to make an informed judgment about whether the financial interest is such that it may affect how a sponsored project is designed, conducted, and reported. If that’s the case, the University will work with you to develop a plan that assures that the project will be free from bias or personal gain resulting from the conflict of interest.