reviewer guide getting started reviewing disclosures post ... · public officers and employees...
TRANSCRIPT
• Getting Started
• Reviewing Disclosures
• Post-Review Actions
• Monitoring Compliance
R E VI EW E R G UI D E
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 2
Contents Welcome! ..........................................................................................................................................3
Section One: Let’s Get Started ............................................................................................................3
What is eDisclose? .................................................................................................................................... 3
What does it do? ....................................................................................................................................... 3
What are the benefits of using eDisclose? ............................................................................................... 4
How does eDisclose work? ....................................................................................................................... 5
Who will provide training and guidance? ................................................................................................. 5
Outside Activity Review Guidance ........................................................................................................ 5
Nepotism Guidance............................................................................................................................... 6
Gifts or Conflicting Business Relationships Guidance ........................................................................... 6
eDisclose Help Desk .............................................................................................................................. 6
Section Two: Accounts .......................................................................................................................7
Create an Account ..................................................................................................................................... 7
Login .......................................................................................................................................................... 7
Forgot your User Name or Password? ...................................................................................................... 8
Section Three: Reviewing Disclosures .................................................................................................9
Review Process Overview ......................................................................................................................... 9
Responding to a Review Request ............................................................................................................ 10
Working with Reviewer Worksheets ...................................................................................................... 13
Completing Your Review ......................................................................................................................... 15
Requesting Clarification .......................................................................................................................... 16
Section Four: Post-Review Actions .................................................................................................... 19
Responding to Clarification Requests ..................................................................................................... 19
Monitoring Compliance .......................................................................................................................... 22
Section Five: Addendums ................................................................................................................. 23
Outside Activity Review Process Overview ............................................................................................. 23
Nepotism Review Process Overview ....................................................................................................... 24
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 3
Welcome! We are pleased to introduce the USF System’s new disclosure system for State of Florida Code of Ethics for Publics Officers and Employees (FCOE) and outside activity disclosures―commonly referred to as eDisclose. You probably have lots of questions about this great new tool: What is it? What does it do? How does it work? What are the benefits of using it? This manual will answer many of your questions, and it will provide you with specific guidance that will help you meet your FCOE and outside activity review responsibilities successfully.
Section One: Let’s Get Started It is important for you to have a baseline understanding of what eDisclose is and what it can do for you. Here are some answers to the most commonly asked questions.
What is eDisclose? eDisclose is an online system for disclosing and reviewing Florida Code of Ethics for Public Officers and Employees (FCOE) and outside activities made by USF System employees. This system assists employees in meeting their annual disclosure and acknowledgement responsibilities under Florida Statute §112.313, USF System Regulation 10.107, and USF System Policy 0-027.
What does it do? The eDisclose system guides and documents employee-disclosed FCOE relationships, the employment of related persons (nepotism), and proposed outside activity. Likewise, the system guides and documents the review of such disclosures by institutional officials. The following complex statutory requirements and restrictions placed upon USF System Employees are addressed within eDisclose:
• Involvement in certain types of business, employment, or contractual relationships;
• Employment of a related person in situations that could lead to nepotism; • Soliciting or accepting gifts; • Misuse of Public Position or Non-Public Information;
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 4
• Engaging in certain outside activities that have the potential to create a conflict of interest or commitment.
Meaning employees use eDisclose to meet their annual FCOE disclosure and acknowledgement requirement; disclose nepotism, and disclose outside activity. USF System administration uses eDisclose to review FCOE, nepotism, and outside activity disclosures in accordance with USF System regulation and policy; and monitor compliance with same.
What are the benefits of using eDisclose? The eDisclose system provides employees with an efficient, effective means of meeting their annual disclosure and acknowledgement requirements under the FCOE and USF System Policy 0-027. Some the benefits of the eDisclose system over the “old” paper-based system are:
• Automated reminders of due dates. • Automated routing of employee disclosures to the appropriate institutional official
for review (the “Reviewers”. • Real-time status updates for employees to know when their disclosures have
been reviewed and the resultant determinations of such reviews. • Automated notifications to let employees and Reviewers know when action on
their part is needed to complete the review of a disclosure. • Process transparency, meaning employees can log in anytime from anywhere
and see who last touched their disclosure, when, and what they did with it. • Reviewers can monitor the compliance of their employees with their FCOE and
outside activity disclosure responsibilities from anywhere and at any time. • Guided review worksheets to assist Reviewers in reviewing each type of
disclosure (i.e., FCOE, nepotism or outside activity). • Email buttons that look like the blue-and-white envelope icon pictured below are
placed throughout so that you can request compliance advice or technical support when you need it.
• Tip buttons that look like the grape-and-white light bulb icon pictured below are
placed throughout to provide you with tips and tricks for using the features of eDisclose or to provide you with guidance on a topic area.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 5
How does eDisclose work? As employees navigate through the eDisclose System they are provided with education pages and then, when appropriate, they are asked a series of questions designed to assist them in determining whether or not their particular situation must be disclosed. Employees disclosing in eDisclose are called “Disclosers”. Institutional Officials responsible for reviewing these disclosures in eDisclose are called “Reviewers”. Based on an employee’s answers, eDisclose forwards disclosures to the appropriate Reviewer as follows:
• Business, Employment, or Contractual Relationship disclosures are forwarded to USF System Compliance & Ethics.
• Nepotism and Outside Activity disclosures are forwarded for sequential review based on the hierarchy of the Discloser’s organizational unit: 1) Supervisor―the Discloser’s direct Supervisor as recorded in GEMS. 2) Manager―the individual responsible for the Discloser’s organizational unit,
e.g. Chair, Dean, Director. 3) Senior Manager-the Provost, Vice President, or Regional Chancellor
responsible for the Discloser’s organizational unit The Reviewer completes their review within the eDisclose system. Once a final review determination has been made, eDisclose will send an automated email to the Discloser requesting that they acknowledge the final review decision. A disclosure will remain open in the system until such acknowledgement is made by the Discloser.
Who will provide training and guidance? Training for the eDisclose system is provided by USF System Compliance & Ethics through its online materials, face-to-face workshops, and consultation via email at [email protected] or by calling 813-974-2705. Guidance for specific compliance topics addressed by the eDisclose system is provided by subject matter experts and is based on the Discloser’s employee type as follows: Outside Activity Review Guidance Reviewers of outside activity disclosures made by Faculty members without a USF Health appointment should contact the USF System Office of the Provost for assistance at 813-974-2145.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 6
Reviewers of outside activity disclosures made by USF Health Faculty should contact USF Health Faculty and Academic Affairs for assistance at 813-974-1676. It is important to remember that USF Health outside activity disclosures are NOT made in the eDisclose system, but rather are made in USF Health’s Reporting Outside Activities Database (ROAD), available online at https://hsccf.hsc.usf.edu/road/ . Reviewers of outside activity disclosures made by Administration, Staff, and Temporary employees contact USF System Compliance & Ethics by emailing them at [email protected] or phoning 813-974-2705. Nepotism Guidance For guidance concerning the review of nepotism disclosures made by Faculty members contact the USF System Office of the Provost for assistance at 813-974-2145. For guidance concerning the review of nepotism disclosures made by Administration, Staff, and Temporary employees contact USF System Compliance & Ethics by emailing them at [email protected] or phoning 813-974-2705. Gifts or Conflicting Business Relationships Guidance Contact USF System Compliance & Ethics by emailing [email protected] or phoning them at 813-974-2705. eDisclose Help Desk Direct technical questions about eDisclose to the eDisclose Help Desk, available during regular business hours at 813-974-9312 and by email at [email protected].
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 7
Section Two: Accounts In order to review a disclosure in eDisclose, you must have an activated USF NetID account.
Create an Account USF Tampa employees without a NetID can request one from USF Information Technology (IT) at the following link: https://netid.usf.edu/una/?display=activate . If you have forgotten your NetID password or need additional assistance with your NetID account, you can contact the IT Help Desk 24/7 by calling 866-974-1222, or by emailing [email protected]. You may also visit the Help Desk in person at the USF Tampa campus Library in room LIB 117. USF St. Petersburg (USFSP) employees without a NetID can request one from the Campus Computing Help Desk by calling 727-873-4357 or by emailing [email protected]. You may also visit them in person at their physical location in BAY 226. USF Sarasota-Manatee (USF-SM) employees without a NetID can request one from USF-SM Technology Services by calling (941) 359-4350 or by emailing [email protected]. USF-SM employees can bring their issues and requests to them for resolution in person on the third floor in room A-304.
Login On the myUSF portal, accessible via http://my.usf.edu:
1) Enter your NetID. 2) Enter your NetID password. 3) Click on the Sign In button to log into myUSF.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 8
When the myUSF Portal opens, choose eDisclose from the Business Systems drop-down menu.
Forgot your User Name or Password? If you ever forget your NetID account credentials, you can always contact your institution’s IT Help Desk:
USF Tampa IT Help Desk [email protected] 866-974-1222; LIB 117
USF Sarasota-Manatee Technology Services [email protected] 941-359-4350; Third floor in A-304.
USF St. Petersburg Campus Computing Help Desk [email protected] 727-873-4357; BAY 226
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 9
Section Three: Reviewing Disclosures It’s important for Reviews to have a baseline understanding of how the overall review process for FCOE, nepotism, and outside activity disclosures functions in eDisclose. Likewise, Reviewers need to know how to use eDisclose to review such disclosures in accordance with the FCOE and USF System regulation and policy.
Review Process Overview The process steps for reviewing employee disclosures are based on the type of disclosure the employee submits in eDisclose: FCOE, nepotism, or outside activity, as follows:
• FCOE disclosures involving Business, Employment, or Contractual Relationships are forwarded to USF System Compliance & Ethics for review.
• Nepotism or Outside Activity disclosures are reviewed sequentially as follows
based on the hierarchy of the Discloser’s organizational unit:
1) Supervisor, which is the disclosing employee’s direct supervisor as assigned in GEMS; then
2) Manager, which is the Chair, Director, Dean, etc. responsible for the
Discloser’s organizational unit; and then 3) Senior Manager, which is the Provost, Regional Chancellor, or Vice
President responsible for the Discloser’s organizational unit. Supervisors and Managers make recommendations to the Senior Manager. Senior Managers are responsible for making a determination on behalf of the institution as to whether or not the proposed outside activity or employment of a related person creates an impermissible conflict of interest; and, if there is such a conflict, determining how, if possible, the conflict may be mitigated or eliminated entirely. For more details about these review processes consult Section Five: Addendums.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 10
Responding to a Review Request When a Disclosure is ready for your review, the eDisclose system sends you an automated email requesting your review. Such emails are sent to the email on record in your GEMS account as established and maintained by Human Resources. Below is an example of what such an automated review request looks like. In this example, the Supervisor, Melissa Supervisor, is being asked to review an outside activity disclosure made by her direct report, John Discloser, on March 25, 2014.
Click on the link to the disclosure provided at the bottom of the email. This will open the Disclosure Workspace for the disclosure needing your attention, provided you are logged in with your NetID; otherwise you will be prompted to login.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 11
Since Supervisors, Managers, and Senior Managers are Disclosers (employees who need to disclose) and Reviewer (institutional officials who review disclosures), you must confirm your role as a Reviewer when you first log into eDisclose by clicking on the eDisclose Reviewer role (1) under My Roles on the left-hand column of your Home Page. This opens your Reviewer Home Page (2). Disclosures needing your review are listed on your My Inbox tab (3). Select the disclosure you wish to review by clicking on its hyperlinked name on the My Inbox tab of your Home Page. This will open the disclosure’s workspace. Below is an example of a Reviewer Home Page, in this case for a Supervisor.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 12
Choose the Review button located on the left-hand column of the Disclosure Workspace to open a Reviewer Worksheet and begin your review.
eDisclose automatically customizes the Review button a Reviewer sees based on the type of disclosure being viewed: outside activity, nepotism, or FCOE. In the below example, a Supervisor is viewing an outside activity disclosure’s workspace; therefore, eDisclose displays the “Complete OA Review” button. Had the Supervisor been viewing a nepotism disclosure, eDisclose would have displayed the “Complete Nepotism Review” button instead.
VS
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 13
Working with Reviewer Worksheets When you choose the Review button, eDisclose will open a customized Reviewer Worksheet based on your Reviewer Type (Supervisor, Manager, Senior Manager) and the type of disclosure you are reviewing (outside activity, nepotism, or FCOE). Every Reviewer Worksheet within eDisclose has three basic sections designed to assist you in your completing your review as follows:
1. Reminder Section. This section provides a brief overview of what you need to do. If you are a Manager or Senior Manager, this section will also provide you with links to reviews completed by previous reviewers of the disclosure.
2. Disclosure Section. This section provides a view-only copy of disclosure and automatically begins on the page you need to first review.
Use the scroll bar provided in this section to navigate the disclosure form.
3. Reviewer Worksheet Section. This section includes instructions on how to
complete the Reviewer Worksheet; a link to guidance regarding how the review process works; questions to guide and document your review; and a place to record your review recommendation or decision.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 14
Answer all questions marked with a red asterisk in the Reviewer Worksheet Section, as these questions are dynamic and will display key guidance as to whether or not the situation described in the disclosure is permissible under the FCOE and USF System regulation and policy. Asterisked questions are also required, meaning you will not be able to submit your review without completing all of them. Based on your answers, the reviewer worksheet provides suggestions for how to the actual or potential conflict of interest or commitment (COI) can be mitigated or eliminated and guidance for your review decision (e.g. approve, approve with conditions, or disapprove). In the below example, the Supervisor has reviewed an outside activity disclosure and has indicated that the proposed activity may create a conflict of interest or commitment (COI). When the Supervisor marked Question 6 as “Yes”, the reviewer worksheet expanded to provide additional questions and guidance.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 15
Completing Your Review At the bottom of the Reviewer Worksheet section is where you must take the following steps to complete your review:
1. Decision Step―Supervisors and Managers indicate their recommendation to the Senior Manager; and Senior Managers indicate their determination.
2. Rationale Step―Reviewers explain the reasoning driving their review. 3. Affirmation Step―Reviewers confirm that their review is complete and ready for
submission. 4. Confirmation Step (not visible to Senior Managers because they are the
terminal reviewers)―Supervisors and Managers confirm that the person listed as the next reviewer in the process is indeed the appropriate person. If not, use the Select button to choose the appropriate reviewer.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 16
When you are ready to submit your review, click the OK button to submit your review to the next reviewer for consideration or, in the case of Senior Managers, complete the review. If you are not ready to submit your review, then click on the Cancel button to return to the Disclosure Page.
Requesting Clarification From your Home Page: Select the disclosure you wish to review by clicking on its hyperlinked name on the My Inbox tab of your Home Page. This will open the disclosure’s workspace.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 17
Choose the Request Clarification button located on the left-hand column of the Disclosure Workspace to open the Request Clarification pop-up window.
eDisclose automatically customizes the Request Clarification button a Reviewer sees based on their Reviewer type: (Supervisor, Manager, and Senior Manager) In the below example, a Supervisor can only request clarifications from the Discloser; therefore, eDisclose displays the “Request Clarification From Discloser” button. When the Manager reviews the same disclosure, eDisclose will instead display the “Request Clarifications From Supervisor” button. For a reminder of how requests are sequentially made between reviewers and the discloser, see Section Five: Addendums.
VS
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 18
On the Request Clarification pop-up window, enter your request in the text box provided and click OK to send your clarification request.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 19
Section Four: Post-Review Actions
Responding to Clarification Requests The next reviewer in the review process may request clarifications from the previous reviewer. When such requests are made, eDisclose will return the disclosure to your Inbox and send you an automated message to the email on record in your GEMS account, established and maintained by Human Resources. Below is an example of what such an automated message looks like. In this example, the Manager is asking the Supervisor to provide more information regarding an outside activity she reviewed in eDisclose.
Click on the link provided in the email to open the workspace for the disclosure needing your attention. If you are not already logged in with your NetID, you will be prompted to do so.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 20
Alternatively, log into eDisclose using your NETID. While on the Inbox tab of your Home Page, click on the name of the disclosure to open its workspace.
Once the disclosure’s workspace is open, the History tab will display a summary of what the Reviewer needs.
To submit your response to the Reviewer, select the Submit Response activity to open the Submit Response window. Type your response in the text box provided and then click OK to submit your response to the reviewer. If you are not ready to submit your response, click on the Cancel button to return to the disclosure’s workspace.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 21
After you have submitted your response to the Reviewer, the Disclosure Workspace will display “Response Submitted” on the History tab as well as by whom and when. The History tab provides a step-by-step summary of what happened to the disclosure during every step of the review process. Similarly, the Current State of a disclosure is always presented on the Disclosure Workspace in the red box on the left-hand column.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 22
Monitoring Compliance Reviewers can monitor the compliance of their direct reports in meeting their disclosure responsiblities under the FCOE and USF System Policy 0-027 as follows:
1. Annual FCOE disclosures―Choose the Annual FCOE Disclosure by Direct Reports tab on your Home page to view a list of annual FCOE disclosures completed by employees who directly report you.
2. Outside Activity disclosures―Choose the Outside Activity Disclosures by Direct Reports tab on your Home page to view a list of outside activity disclosures completed by employees who directly report you.
Use % as a wild card to filter information on the above tabs. E.g. Enter “%Smith” into the filter field to find all disclosures by your direct reports with the surname “Smith”.
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 23
Section Five: Addendums
Outside Activity Review Process Overview
The Employee completes and submits a new Outside Activity Disclosure.
The employee’s direct Supervisor (as assigned in GEMS) reviews the Outside Activity disclosure; and completes and submits a Supervisor Review Worksheet. Supervisors may request additional clarifications from the Employee.
The Chair, Director, Dean, etc. responsible for the
employee’s organizational unit (the “Manager”) reviews the Outside Activity disclosure, the Supervisor’s Review Worksheet and recommendation, and completes a Manager Review Worksheet. Managers may request additional clarifications from the Supervisor.
The Provost, Regional Chancellor, or Vice President responsible for the employee’s organizational unit (the “Senior Manager”) reviews the Outside Activity Disclosure, the Supervisor and Manager Review Worksheets and recommendations; and completes the Senior Manager Review Worksheet. Senior Managers may request additional clarifications from the Manager.
The Employee acknowledges the determination
made by the institution. Need more information? Questions regarding faculty outside activity disclosures should be directed to the Office of the Provost by calling 813-974-2145. Alternatively, USF System Compliance & Ethics is available to assist Reviewers at [email protected] or 813-974-2705.
Employee Disclosure
Supervisor Review
Manager Review
Senior Manager Review
Employee Acknowledgement
eDisclose Reviewer Guide | University of South Florida System | Last Updated 3/28/14 24
Nepotism Review Process Overview
The Employee completes and submits a Nepotism Disclosure.
The employee’s direct Supervisor (as assigned in GEMS) reviews the Nepotism disclosure; and completes and submits a Supervisor Review Worksheet. Supervisors may request additional clarifications from the Employee.
The Chair, Director, Dean, etc. responsible for the
employee’s organizational unit (the “Manager”) reviews the Nepotism disclosure, the Supervisor’s Review Worksheet and recommendation, and completes a Manager Review Worksheet. Managers may request additional clarifications from the Supervisor.
The Provost, Regional Chancellor, or Vice President responsible for the employee’s organizational unit (the “Senior Manager”) reviews the Nepotism Disclosure, the Supervisor and Manager Review Worksheets and recommendations; and completes the Senior Manager Review Worksheet. The Senior Manager may request additional clarifications from the Manager.
The Employee acknowledges the determination
made by the institution. Need more information? Questions regarding faculty nepotism disclosures should be directed to the Office of the Provost by calling 813-974-2145. Alternatively, USF System Compliance & Ethics is available to assist Reviewers at [email protected] or 813-974-2705.
Employee Disclosure
Supervisor Review
Manager Review
Senior Manager Review
Employee Acknowledgement