Information for managers on NSF and NIH harassment reporting
The National Science Foundation and the National Institutes of Health have implemented new measures over the last several years to ensure the research and learning environments they support are free from harassment. These measures include requiring awardee organizations to report findings and determinations of harassment and other conduct.
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How does UAB ensure compliance with these requirements?
The Office of Sponsored Programs (“OSP”) and Human Resources (“HR”) coordinate to provide the required harassment reporting to NSF and NIH.
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What is my responsibility as a manager?
- Reporting through appropriate channels any conduct that might constitute a violation of UAB policy
- Immediately reporting allegations of harassment, bullying, retaliation, or hostile working conditions to HR
- Supporting and helping facilitate official HR investigations and implementing any necessary interim or disciplinary measures
- Managers are not responsible for reporting information directly to NSF or NIH.
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Which forms of harassment must be reported to NSF and NIH?
- NSF Requires awardee organizations to report findings of sexual harassment, sexual assault, and other forms of harassment. This also includes reporting imposed administrative leave or action as part of a finding, investigation, or alleged violation
- NIH requests for prior approval must mention whether changes are related to concerns about harassment, bullying, retaliation, or hostile working conditions. Notice is required within 30 days when a PD/PI or other Senior/Key personnel is removed from their position or otherwise disciplined due to the aforementioned concerns
The UAB Enterprise Conflict of Interest and Conflict of Commitment opens a new website policy was revised in January 2021 to require certain UAB employees to “review and recertify disclosures of financial interests annually” while maintaining a role of full-time faculty, investigator, or institutional official. This additional annual requirement is the mechanism by which these annual disclosures are reviewed and recertified.
View step-by-step instructions for investigators and institutional officials and full-time faculty for completing the annual requirement e-form. The Office of Research's website opens a new website may also be referenced for additional information.
Employees were instructed via direct e-mails to submit the new annual disclosure by September 15, 2023. and have been sent reminder e-mails. After September 15, 2023, failure to complete the annual requirement may preclude the submission of research proposals to funding agencies, and it may result in the rejection of IRB submissions if a noncompliant investigator is listed as key personnel on the protocol.
Frequently Asked Questions
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Why is this additional annual requirement necessary?
The UAB Enterprise Conflict of Interest and Conflict of Commitment Policy opens a new website was revised in January 2021 to require certain UAB employees to “review and recertify disclosures of financial interests annually” while maintaining a role of full-time faculty, investigator, or institutional officials. This additional form is the mechanism by which these annual disclosures are reviewed and recertified.
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How do I access the form?
Log into the UAB Forms Dashboard opens a new website (uab.edu/uabforms) using your Blazer ID and password. Please note the dashboard is only accessible via on-campus network or UABSecureAccess VPN. Instructions are provided on the UAB Forms Dashboard.
For more information on connecting to the UAB SecureAccess VPN, visit UAB IT's Virtual Private Network opens a new website page.
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Who do I contact if I am having problems accessing the form?
Please make sure you are accessing UAB Forms Dashboard opens a new website (uab.edu/uabforms) via the on-campus network or UABSecureAccess VPN. Further questions regarding general and technical use of UAB Forms Dashboard should be directed to
This email address is being protected from spambots. You need JavaScript enabled to view it. or (205) 996-5555. -
How do I know if I am an institutional official or designated employee?
Institutional Officials: This includes any employee with direct authority over allocation of institutional resources, assignments of graduate students, trainees, funding, space, salary, or promotions for faculty. Institutional officials include the University President, University Provost, University Vice Presidents, Deans, Chairs, and other administrators in key decision-making, signatory, or assurance roles, as determined and notified in writing by the Chief Risk & Compliance Officer in consultation with the University President.
Designated Employee: Certain employees who are not investigators, institutional officials, or full-time faculty members have been included in the annual requirement based upon their role and job responsibilities.
All individuals who must complete the annual requirement are notified by email.
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I do not believe I am an institutional official, full-time faculty member, other designated employee, or investigator. Why did I receive an email prompting me to complete the annual requirement e-form?
You received the email because you have been categorized as an institutional official, full-time faculty member, other designated employee, or investigator.
If you are categorized as an institutional official (i.e., University President, University Provost, University Vice Presidents, Deans, and Chairs) or other designated employee, you were notified separately by the Chief Risk & Compliance Officer.
Please note that “investigator” is defined broadly and is not limited to principal investigators (“PIs”), and may include those individuals designated as responsible personnel on research projects with which they are associated. If you have additional questions about why you were designated as an investigator or you believe you are no longer in a role that qualifies as an “investigator,” please contact the Office of the Conflict of Interest Review Board (OCIRB) in the Office of Research at (205) 975-9692 or
This email address is being protected from spambots. You need JavaScript enabled to view it. . -
If I have already received approval for an external activity involving a foreign entity, do I still need to disclose it in the Annual Requirement e-form?
Yes. Although you have already received approval for a foreign external activity within the external activity workflow, you must still disclose the foreign affiliation to ensure it is entered in the Annual Requirement workflow.
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What if I did not submit an external activity request form, and I did not receive approval for an external activity before participating in the activity?
While the UAB Enterprise Conflict of Interest and Conflict of Commitment opens a new website policy requires advanced approval prior to participating in external activities, UAB encourages full transparency at any time. The external activity request form will allow an after-the-fact submission. Accordingly, requests must be submitted after-the-fact to ensure correct disclosures have been made to the institution. For individuals responsible for research, changes in financial interests, which includes payments related to external activities, must be disclosed within thirty (30) days of the change.
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Does Intellectual Property that has already been disclosed to the UAB Harbert Institute for Innovation and Entrepreneurship (HIIE) need to be reported again in the Annual Requirement e-form?
No.
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If I have completed my Annual Requirement e-form incorrectly, how do I correct it?
There is no process for modifying a submitted form so a new form must be submitted. Please return to the UAB Forms Dashboard opens a new website (uab.edu/uabforms) using your Blazer ID and password to complete a new Annual Requirement e-form. Please submit the corrected version.
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Is the Annual Requirement e-form related to the Statement of Economic Interest Form?
No. The Statement of Economic Interest Form is required annually by the Alabama Ethics Commission. The answers provided in the Statement of Economic Interest Form go to the Alabama Ethics Commission. Those answers gathered in the Statement of Economic Interest Form are not provided to UAB.
In contrast, the Annual Requirement e-form is a UAB internal e-form required by the UAB Enterprise Conflict of Interest and Conflict of Commitment opens a new website policy. The answers provided in the Annual Requirement e-form are used by UAB administrative offices to determine whether a conflict of interest or conflict of commitment exists.
The Federal Acquisition Regulation (FAR) is a set of governmental requirements that UAB, as an organization that provides goods or services to the U.S. government, must follow. These requirements apply to federal contracts. The UAB Enterprise Code of Conduct and its expectation that UAB employees will raise ethical questions or concerns is particularly relevant to the selected FAR provisions that appear below:
Significant FAR Requirements
FAR 52.203-13: Contractor Code of Business Ethics and Conduct, and FAR 52.204-14: Display of Hotline Poster
- Code of Business Ethics and Conduct (FAR 52.203-13(b)(1)(i))
Requires contractors to have a written code of business ethics and conduct, and make a copy of the code available to each employee engaged in the performance of the contract. - Training (FAR 52.203-13(c)(1))
Requires an ongoing business ethics and compliance program, including conducting effective training programs on the contractor’s standards and internal control system. The training shall be provided to the contractor’s principals and employees, and as appropriate, the contractor’s agents and subcontractors. - Periodic Reviews (FAR 52.203-13(c)(2)(ii)C))
Contains specific requirements for companies to perform periodic reviews of company business practices, procedures, policies, and internal controls, including:- Monitoring and auditing to detect criminal conduct;
- Periodic evaluation of the effectiveness of the business ethics awareness and compliance program and internal control system (especially if criminal conduct has been detected); and
- Periodic assessment of the risk of criminal conduct, with appropriate steps to design, implement, or modify the business ethics awareness and compliance program and the internal control system as necessary to reduce the risk of criminal conduct identified through this process.
- Internal Reporting Mechanism (FAR 52.203-13(c)(2)(ii)(D))
Requires the contractor’s internal control system to provide for an internal reporting mechanism, such as a hotline, which allows for anonymity or confidentiality, by which employees may report suspected instances of improper conduct, and instructions for employees to make such reports. - Disciplinary Action (FAR 52.203-13(c)(2)(ii)(E))
Requires contractor’s internal control system to provide for disciplinary action for improper conduct or for failing to take reasonable steps to prevent or detect improper conduct. - Disclosure of Improper Conduct (FAR 52.203-13(c)(2)(ii)(F))
Provides detailed requirements for making timely disclosure of improper conduct. This provision requires contractors to disclose, in writing, to the agency Office of the Inspector General, with a copy to the contracting officer, whenever the contractor has credible evidence that a principal, employee, agent, or subcontractor has violated Federal criminal law involving fraud, conflict of interest, bribery, or violations with the gratuities regulations or the False Claims Act (FAR 52.203-13(c)(2)(ii)(F)).
As public employees, UAB employees must adhere to the State of Alabama Ethics Law. Additional information is available from the Alabama Ethics Commission and under the tabs below.
Resources
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Legal Duty to File Statement of Economic Interest
As a public institution, UAB employees who meet certain criteria are required to file an annual Statement of Economic Interests (SEI) with the Alabama Ethics Commission. The SEI should be filed annually in addition to any other disclosures required by UAB policy. For more information, including filing criteria and ways to file, visit the UAB Human Resources Alabama Ethics Requirement opens a new website webpage.
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Proof of Mandatory Online Ethics Training within 90 days of Date of Hire
Public employees who are required to file a Statement of Economic Interests opens a new website are also required to participate in an online educational review opens a new website of the Alabama Ethics Law within 90 days of their hire date.
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Gifts to Public Employees
Information on the 2010, 2011, and 2012 Amendments to the Ethics Act opens a new website contain rules regarding conflicts of interest, public contracts, lobbying activities, and restrictions on gifts to public employees.
Public employees may not solicit or receive anything for the purpose of corruptly influencing official action, regardless of whether or not the thing solicited or received is a thing of value. Family members of public employees may not receive anything given to them for the purpose of corruptly influencing official action. No public employee shall, other than in the ordinary course of business, solicit a thing of value from a subordinate or person or business with whom he or she directly inspects, regulates, or supervises in his or her official capacity. Excluded from the definition of “thing of value” are meals at educational functions/workshops/widely attended functions or items or services of de minimis value, or meals under $25 (maximum of $50 per year).
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Use of UAB Position or Property for Personal Gain
The Alabama Ethics Law opens a new website says state employees cannot receive personal gain for themselves or members of their families as a result of their state employment. Some actions that may have implications under this provision of the Alabama Ethics Law are:
- UAB employees selling instructor editions or complementary copies of textbooks provided by textbook publishing companies
- UAB employees selling faculty-staff athletics tickets for more than the employee paid for them or giving faculty-staff athletics tickets to anyone and receiving something of value in return
- Using UAB property or personnel for the purpose of compensation from sources external to UAB or for other private benefit
- Using or permitting the use of UAB’s name in a way that would suggest the activity is sponsored or endorsed by UAB
- Entering into a contact with a business associated with a UAB employee or a family member of a UAB employee that will be paid for using government funds, unless the contract has been awarded through the state’s competitive bidding process
It is a violation of the UAB Enterprise Code of Conduct opens a new website for a faculty or staff member to exploit students for their private advantage. A faculty or staff member should also acknowledge significant assistance from students, demonstrate respect for the student as an individual, and assure that evaluation of that student reflects their true merit. See 3.6 Standards of Behavior – Faculty Handbook opens a new website for additional information.
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Acceptable Use of UAB Property
UAB computer and network devices may only be used for work related to the university or for other approved activities. All files and information composed, transmitted, accessed, received or stored in these systems are the property of UAB. Use of UAB equipment for personal commercial purposes or for personal financial or other gain is strictly prohibited. For additional information, review UAB’s policy on Acceptable Use of Computer and Network Resources opens a new website.
Employees are prohibited from engaging in inappropriate conduct regarding the use of state property. The following conduct and may be disciplined, up to and including dismissal:
- Dishonest acts
- Appropriating state or student equipment, time, or resources for personal use or gain
- Misusing or neglecting UAB property, funds, materials, equipment or supplies
- Stealing or possessing without authority any equipment, tools, materials or other UAB property or attempting to remove them from the premises without approval or permission from the appropriate authority. See the Equipment Accounting Policy opens a new website.
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Rules for Warehousing UAB Property
As a state-funded entity, employees are prohibited from throwing away or discarding UAB property. When items are no longer useful to a department, they may be sent to the Surplus Warehouse opens a new website and then sold to the public. The only way an item that was purchased with state funds can be sold is to offer it to the general public through a public auction. For more information, review UAB’s policies on:
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University Policies on Patents, Copyright, and Intellectual Property
Intellectual property generated during the course of your employment may also be owned by UAB. Become familiar with the following patent, copyright, and intellectual property policies:
- UAB Enterprise Conflict of Interest Conflict of Commitment Policy opens a new website
- Patent Policy opens a new website – Board Rule 509
- Copyright Policy opens a new website
- Expectations for Research Sponsors – IRB Policy 005 opens a new website
- 3.9 Ownership of Intellectual Property Rights (Patent Policy) opens a new website – Faculty Handbook
- 3.10 Copyright opens a new website– Faculty Handbook
Please note that UAB policies require disclosure of intellectual property opens a new website developed using UAB funds or resources.
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Political Activity
According to University of Alabama Board Rule 304 opens a new website, all UAB employees and faculty are prohibited from the use, or appearance of the use, of the UAB name or resources in support of a political campaign or organization. This rule recognizes the civil and political rights and responsibilities of UAB personnel and encourages them to fulfill their responsibilities as private citizens. It prohibits, however, the use or appearance of use of UAB resources, time, or property for or on behalf of any political candidate, campaign, or organization or for any contribution or solicitation of any contribution to a political campaign or organization.
No UAB employee shall lend or appear to lend the support of UAB in connection with any contribution or solicitation of any contribution to a political campaign or organization. When an employee is involved in political activity, it is incumbent upon them to make clear that they are acting in a private and individual capacity and that their activities have neither UAB sponsorship nor support.
UAB employees may not seek or hold public office and remain employed at UAB if such activities could or would result in a conflict of interest or interfere with the employee carrying out his University responsibilities. Employees who intend to seek election to public office must first obtain written consent from the University of Alabama Chancellor through appropriate reporting channels.
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Employment of Members of the Same Family
Alabama Code, Section 41-1-5 opens a new website, prohibits an employee of UAB from hiring or entering into a personal service contract with any person related to them within the fourth degree to any job with UAB. If this rule is violated, the appointment is deemed void and the person can be charged with a misdemeanor and fined up to $500 and imprisoned for up to one year.
UAB policy provides that individuals who are related by blood, marriage, adoption, or who reside in the same household are permitted to work in the same department provided no nepotistic conduct occurs and a nepotism management plan is created. For more information on what constitutes nepotistic conduct, review Nepotism – HR Policy 123 opens a new website and Nepotism at UAB opens a new website.
Additional information on Conflicts of Interest is available in University of Alabama System Board Rule 106 opens a new website and UAB Enterprise Conflict of Interest Conflict of Commitment Policy opens a new website.
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Reporting Ethics Violations
If you see or suspect unethical or illegal behavior in violation of the Alabama Ethics Law, report your concerns to your department chair, Dean’s office, or anonymously through the UAB Hotline opens a new website.
If the University becomes aware of a violation of the Alabama Ethics Law, it must report the matter to the State Ethics Commission opens a new website.