Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Article I - Purpose. We may communicate, electronically or via telephone with you about your benefit plan, programs, products, or services that are or may be available to you in connection with your transactions with us including, but not limited to, Online Services updates, general wellness reminders or information, prescription reminders, appointment reminders, general health information, newsletters, and surveys. Immediate Family:6An educational institution in any state that. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. These safeguards vary based on the sensitivity of the Information that is being collected, used, and stored. This request may be made no more than once per calendar year. It is your responsibility to safeguard the devices you use to access our Online Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. This information may include demographic data, technical information about the technology (e.g., phone, computer) you use to connect to the Online Services, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (collectively, "Activity Information"). 28 of the IDD Directive "Conflicts of interest" - - and to art. Any further questions about your account, claims or benefits or request for additional information can be addressed by visiting your member or patient website or calling the toll-free member phone number on your health plan or member ID. a health-policy researcher. <>
Conflict of Interest Policy. For purposes of its conflicts of interest analysis, UnitedHealthcare refers to the Federal Acquisition Regulation Part 9.5, which defines three (3) types of OCIs that are recognized and . Conflict of interest: A significant financial interest that could directly compromise or bias professional judgment and objectivity related to the management of federal financial assistance. A potential COI relative to NFE procurement is presented in the following circumstances: A NFEs employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract. We may change this Policy at any time. Mq t/4='/7wO^l6zO.??N.7wFjqz<=MWggf2(eL5e. For the potential COIs described in Sections 4.0, NFE must provide HRSA with any information regarding its plan and/or measures taken to eliminate, mitigate or otherwise resolve the COI. No employee, officer, or agent of the NFE may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest. If a Conflict is identified, the employee and chair collaborate to develop a written plan describing how the Conflict will be reduced, eliminated, or appropriately managed. Employees are subject to the Political Neutrality Policy. Using non-public information acquired in connection with university business (e.g., confidential personal records, knowledge of forthcoming programs, site selections, and contractor selection) for the benefit of the employee or a Related Party or other unauthorized purposes before public announcements. An NFE receiving federal assistance from HRSA must comply with the HRSA written policy on conflict of interest. This policy provides guidance for all part-time, full-time, and student employees for identifying . We are not liable for the illegal acts of third parties such as criminal hackers. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. This policy addresses these potential situations and how the NFE should address them: The selection, award and administration of contracts by NFEs.7, Procurement actions presenting organizational COIs in relation to a parent, affiliate or subsidiary organization that is not a state, local government or Indian tribe.8. If it is determined that a conflict of interest Secondary Employment means any employment or work, including self-employment, other than an employees primary position at the university. Incidental Use of university property and equipment is generally permissible when it does not conflict with normal university activities. Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the Online Services. Research conflicts involving financial interests by the University or key individuals. 2. 127 0 obj
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In either case, the NFE should take steps to mitigate the situation. Provide a password for the new account in both fields. State:1Any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments. This information can be found in the Specific Product Privacy Notices section of this Privacy Policy. C. Faculty Conflict of Commitment Policy ETHICS STATEMENT In Denmark, the study received approval from the Danish Data Protection Agency (journal numbers 2014-41-3488, 2015-57-0002) for the analysis of registry-based data and an approval from the Danish Patient Safety Board to access medical records for the validation study . Conflict of Interest. For example, we may pre-populate certain demographic information in an online form or make health or medical information viewable on the Online Services that you have provided to us on paper forms or maintained in other information systems. We encourage you to read, share, follow us and provide commentary on Facebook, Twitter, Pinterest, Instagram and other social media sites ("Social Media Site"). Situations that raise concerns about the appearance of a loss of impartiality. In addition, you may also have additional means to manage the collection of Activity Information by: Please note that we do not currently respond to web browser "Do Not Track" signals that provide a method to opt out of the collection of Information about online activities over time and across third-party websites or online services because, among other reasons, there is no common definition of such signals and no industry-accepted standards for how such signals should be interpreted. and. Registration Code . We also may obtain Information that is automatically collected through the Online Services. The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from visitors of our Online Services or to enable certain features of our Online Services. "Need-to-Know" Policy: Maintaining the confidentiality of non-public confidential Here below is presented a non-exhaustive list of situations that may create a Conflict of Interest: Fundraising - A conflict of interest can arise between a fund manager that seeks to maximize the size of the fund in order to increase the amount of management fees generated by the fund and the fund's investors that seek to limit the size of the fund to ensure that . Use of screen, e.g., what points are touched, frequency, etc. If a Conflict is identified, the employee and supervisor collaborate to develop a written plan describing how the Conflict will be reduced, eliminated, or appropriately managed. Read our HIPAA Notice of Privacy Practices to learn more about our privacy practices regarding health and medical information under HIPAA. ; and, Mobile Device Identifier, e.g., UDID, Android ID; and. HRSA will ordinarily respond to this communication within 30 calendar days of the disclosure, unless a longer period is necessary due to the complexity of the situation. Unless otherwise provided by contract, a faculty member may (with prior written approval of the department chair) spend up to four days per month on Secondary Employment while under contract. Pass-through entities (including states) must require that subrecipients disclose potential COI described in Sections 4.0 to them within 30 calendar days of discovery of the potential COI and in accordance with the terms and conditions of their award. The officers, employees, and agents of the NFE may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts. 1. This policy supplements and does not replace or supersede conflict of interest requirements in program statutes and regulations. A Conflict of Interest transaction is a transaction with the College in which a Trustee or other Covered Person has a material interest. It requires that awarding agencies establish conflict of interest policies for federal awards that: Address conditions under which outside activities, relationships, or financial interests are proper or improper; Following an employee's disclosure of a proposed endeavor or activity that may create a conflict of interest, the reviewer will determine whether the proposal: does not present a conflict of interest; presents a possible or actual conflict of interest; or additional review is warranted. Any information you provide, including any personal information, will be transferred to and processed by a computer server located within the United States. For example, you may input a telephone number or email address into a webform or enter information into a chat functionality. A conflict of interest occurs This should ordinarily be the Project Director as the Authorized Representative of the NFE. 4 0 obj
In turn, pass-through entities must disclose subrecipient COIs to HRSA within 30 calendar days of receiving notification of a potential COI by the subrecipient unless HRSA approves, at the request of the pass-through entity, a longer period of time to resolve and/or disclose the COI. Non-cash contributions or donations of property (including donated surplus property); Other financial assistance (except assistance listed in 45 CFR 75.2(b). Recognizing, disclosing, and managing employee conflicts of interest is a crucial part of maintaining integrity on campus and reinforcing a culture of professionalism and the proper use of university resources. We will not intentionally collect any personal information (as that term is defined in the Children's Online Privacy Protection Act) from children under the age of 13 through our Online Services without receiving parental consent. Contain any third-party material including logos, drawings, tattoos, photographs, pictures, sculptures, paintings and other images or works of art, phrases, trademarks, trade secrets, or other items without explicit, prior, written permission to use such materials; Contain sexually explicit, graphic, gratuitous or unnecessarily violent content or defamatory or derogatory content against any ethnic, racial, gender, religious, sexual orientation, professional or age group, or contain any pornographic or nude material; Contain any private information about yourself or any other individual, including without limitation, information related to the health of the individual, financial information about the individual, or any identification or account numbers related to the individual, with or without their permission or consent; Contain any software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software, hardware, or telecommunications equipment; and. Assistance that NFEs receive or administer in the form of: For 45 CFR 75.202 and subpart F, Federal financial assistance also includes assistance that NFEs receive or administer in the form of: Federal financial assistance does not include amounts received as reimbursement for services rendered to individuals as described in45 CFR 75.502(h) and (i)(relating to Medicare and Medicaid payments for providing patient care services). Dadaab, Garissa, Kenya. Your posts and user content must adhere to the following requirements and cannot: We reserve the right to edit comments for content, remove off-topic contributions, delete offensive comments or remarks, block offensive contributors, and delete actual or suspected spam content from any Social Media Site. While conflict of interest is possible in a variety of academic pursuits including the desire for professional and scholarly advancement, acquisition of research funding, recognition by peers, etc., the Conflict of Interest Policy at Mayo Clinic addresses only disclosed financial interests related to research, clinical practice, 2023 Optum, Inc. All rights reserved. Our Online Services may permit you to select how you would like to receive certain communications. Please contact your plan for a copy of its HIPAA Notice of Privacy Practices. endstream
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<. We gather Activity Information about you to improve the quality of our services, such as the best method and time to contact you. Optum Insight's Payment Integrity ("Optum") . ?F?mf7pv?l?A?Mf?|vzYOzy,Kh$'LOz~WGy~;6 HRSA established this Federal Financial Assistance Conflict of Interest Policy (COI Policy) pursuant to 45 CFR 75.112. Contain any advertising, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or promote illegal activity and/or illegal contests, sweepstakes, gambling, including any online casino, sports books, bingo, poker, or any other form of solicitation. Supervisors should understand their employees work assignments and factors relevant to Conflicts and Outside Activities. Related Party also includes corporations and other business entities in which an employee has an ownership interest that exceeds 10 percent. Financial Conflict of Interest and the Management Plan will be communicated As an additional account authentication option, we may offer voice recognition technology that can capture your voiceprint and use it to identify you when you call us to access your account. University Trademark Policy \(pdf\) You may always visit this Policy to learn of any updates. We define a conflict of interest as arising from any relationship authors, reviewers or editors have which interferes with, or could reasonably be perceived as interfering with, the full and objective presentation, peer review, editorial decision-making, or publication of a manuscript. Faculty members are expected to be accessible to students, both by keeping regular office hours and by being available in person at other times on campus. Secondary Employment involving endorsements or the employees affiliation with the university is subject to the Advertising, Selling, Soliciting Policy. aq. Policy Statement This policy identifies the actions required by PMI for stakeholders participating in any Thereafter, employees are required to disclose all Outside Activities and Conflicts of Interest annually. Where HRSA-funded public health research is concerned, this policy aligns with the requirements of42 CFR part 50 subpart F. For the purposes of this COI Policy, institutions of higher education that are instrumentalities of a state under applicable state laws are subject to the requirements applicable to such entities. Failure to make required disclosures may result in any of the remedies described in. In addition to the Information identified above, we may collect the following Information: We may obtain location data from your device to provide location-related services (e.g., driving directions or distance calculation, via the mobile application). W6vQ*Rp$YA+52ogV6j&JE89h0)
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s0R2x7MHp We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge. We may use Information to contact you through any contact information you provide through our Online Services, including any email address, telephone number, cell phone number, or fax number. Academic Vice President, Administration Vice President and CFO, Assistant to the President and General Counsel, Human Resource Services, Office of the Associate Academic Vice President Faculty Development, Integrity and Compliance Office, Disclosure, Management, and Review of Conflicts of Interest and Outside Activities, Running for Public Office and Working on Political Campaigns, Faculty Performance Annual Reviews Policy, Financial Conflict of Interest in Sponsored Research Policy, Appropriate Use of Information Technology Resources Policy, Administrative and Staff Employee Leaves Policy, Negotiating, influencing, or attempting to influence the negotiations of contracts or agreements between the university and a third party for the benefit of the employee or a Related Party (. If it is determined that a conflict of interest exists, then, the Director of OCWR or his/her designee, will request that the Investigator For more information about third-party advertising networks and similar entities that use these technologies, see, Managing the use of "flash" technologies, with the. The policy sets boundaries around potential employee and board member conflicts that may arise to prevent legal liabilities and discordance between a .
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may review Optums State Consumer Privacy Notice, Language Assistance / Non-Discrimination Notice, Asistencia de Idiomas / Aviso de no Discriminacin, Additional Rights for California Residents, How to Learn about Health and Financial Privacy Practices, Optum Arizona Community Centers HIPAA Notice of Privacy Practices, Optum California HIPAA Notice of Privacy Practices, Optum Care Cancer Care HIPAA Notice of Privacy Practices, Optum Care Lung and Allergy HIPAA Notice of Privacy Practices, Optum Care Medical Group HIPAA Notice of Privacy Practices, Optum Care Orthopaedics and Spine HIPAA Notice of Privacy Practices, Optum Primary Care Arizona HIPAA Notice of Privacy Practices, Optum Care Utah Sandy HIPAA Notice of Privacy Practices, Optum Colorado HIPAA Notice of Privacy Practices, Optum Florida HIPAA Notice of Privacy Practices, Optum New Mexico HIPAA Notice of Privacy Practices. The purpose of the conflict of interest policy is to protect the FIRST's (Organization) interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the Organization or might result in a possible excess benefit . This policy provides guidance for all part-time, full-time, and student employees for identifying conflicts of interest and establishes the process for disclosing and managing them. This policy applies to all university employees (full- and part-time faculty, staff, and students). For full-time administrative and staff employees, that minimum is 40 hours per week, except for limited cases permitted by the university and documented in writing. Employees who pursue Secondary Employment that interferes with the commitment of primary professional responsibility to the university may request a personal leave or a salary reduction as a temporary solution. Adjunct faculty are not required to disclose Secondary Employment. In that case, the ads will just not be tailored. We also may make certain information available to you on the Online Services that we collect from other sources. We may also share Information with other third-party companies with which we have a business relationship or hire to perform services on our behalf. Use of university information technology resources is subject to the Appropriate Use of Information Technology Resources Policy. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. We may also use third-party analytics companies to provide these services. Faculty service on editorial boards related to the faculty members area of scholarship is likely not a Conflict of Interest but still requires disclosure. We do not control the placement of any marketing or advertising displayed on our pages by social media or third-party organizations.. The inclusion of a link on our Online Services or the ability to utilize a third-party website or software application through our Online Services does not imply that we endorse, or otherwise monitor the privacy or security practices of that third-party website or software application or the accuracy of its content, and your use of the third-party website or software application is governed by the third-party's privacy policy. An organizational potential COI is presented where, because of relationships with a parent company, affiliate, or subsidiary organization that is not a state, local government, or Indian tribe, an NFE is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our Online Services. 4 of the Commission Delegated Regulation ( UE) 2017/2359 of September 21st, 2017 - "Conflicts of interest policy" supplementing the IDD Directive with regard to information - Read our Financial Notice of Privacy Practices as it applies to companies within Optum Financial, Inc., including Optum Bank, Inc., that operate as regulated financial institutions.. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. A potential COI is presented where the employee, officer, or agent of the NFE is involved in a particular matter involving specific parties and the employee, officer, or agent of the NFE knows (or should know) that: NFE actions in situations that raise potential COI concerns: A potential COI should be considered by the NFE as to whether it is truly a COI or a perceived COI. If a Conflict is identified, the part-time faculty member and chair collaborate to develop a written plan describing how the Conflict will be reduced, eliminated, or appropriately managed. Meanwhile, Optum is preparing to defend its $13 billion deal . Refresh has since been valued at $1.2 billion, according to an Axios report. The policy sets boundaries for employees where possible conflicts may arise in order to protect the company and prevent clashes between a company and its workers. Applicable Policy: Institutional Conflicts of Interest in Research Policy. How the most innovative providers are creating value. Describe plan and/or actions taken to eliminate, mitigate or otherwise resolve the COI. Purpose USFHA is committed to sustaining an ethical organization free . If applicable, employees must follow department procedures that address the specific use of department-controlled university property and equipment.
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