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Rules and Policies

School of Medicine


University of Colorado Conflict of Interest Disclosure Rules

         All faculty members must complete an annual conflict of interest disclosure form with the University of Colorado Denver.  Faculty members must disclose all financial ties and interests, regardless of amount, including salary or payment for services, consulting fees, royalty income, honoraria, payments for speaking, consulting and travel, service on boards, gifts, stock and equity interests.  Financial interests of family members must also be reported.  Importantly, faculty members must complete and sign the annual disclosure form, even if there are no financial ties, interests or conflicts to report.

         Professional Research Assistants (PRAs) and staff members who participate in basic or clinical research or who negotiate or execute research agreements on behalf of the University must also submit annual disclosure reports. 

         Changes, additions or elimination of activities or interests must be reported by submitting an updated evaluation form within 30 days of the change, addition or elimination. 

          For more information about annual conflict-of-interest reporting, including definitions, lists of inclusions and exclusions and answers to frequently asked questions, visit the University of Colorado Denver Conflict of Interest and Commitment Office website at:

​Assignment of Income to CU Medicine

All University-paid full-time faculty (at least 50% FTE) are required to sign a University of Colorado Medicine (CU Medicine) full Member Practice Agreement (MPA), which obligates the faculty member to assign all service income to CU Medicine (except while on official leave of absence or while employed by one of the SOM'S core affiliate hospitals).  One exception to this policy is exempt honoraria, as defined below, which does not need to be assigned to CU Medicine.

Exempt honoraria are generally modest payments which are provided by non-profit organizations in exchange for single-occurrence, non-recurring presentations by accomplished faculty who have achieved a level of expertise sought by others outside the University.  Exempt honoraria are limited to one-time payments for lectures, articles, visiting professorships and service on boards for non-profit organizations.  Exempt honoraria also include compensation for one-time or recurring reimbursements for participation on NIH, Veterans Administration and other governmental study sections, as well as royalty and licensing fees and other income from publications, editorial services, patents, copyrighted materials and trade secrets, provided that the faculty member is in compliance with the University’s policies for commercializing intellectual property.

Consulting, service and speaking income that is paid by any for-profit corporation or entity, even on a one-time basis, is not considered exempt and must be assigned to CU Medicine.  Industry-paid speaking engagements are covered under separate policies and are always assignable income.  

Please contact Cheryl Welch (​) if you have any questions regarding exempt honoraria.

School of Medicine Policy on Industry-Paid Speaking Engagements

          The School of Medicine Conflict of interest policy for health care professionals and industry representatives (PDF) prohibits SOM faculty members from accepting free meals, drug samples, travel or gifts from manufacturers of pharmaceuticals, medical devices, nutritional supplements or medical devices. 

          The policy also prohibits Speakers' Bureau participation by School of Medicine faculty, except in limited circumstances.  All industry-paid speaking engagements must be approved, in advance, by the Industry Talk Approval Committee.

          Approval of non-marketing speaking engagements will be considered by the Industry Talk Approval Committee if the talk represents a genuine service to the community and is solely for educational purposes.  Approval will not be granted for talks that focus on specific products, if the speaker is required to use any slides or other materials provided by industry, or if the slides or other content are subject to approval by industry.  

Note: If your talk meets any of the following criteria, your talk is exempted from the Speakers' Bureaus policy and you do not need to submit your talk for approval:

  1. Research consulting (defined as an activity that focuses on planning, conduct or analysis of a clinical or scientific investigation or dissemination of the results of an investigation performed or coordinated by you).
  2. Approved Continuing Medical Education (CME) program, and you are allowed to change the content of your slides or presentation without review and approval by industry.
  3. Compensation for presentation will come directly from an academic institution, non-profit organization, or professional society (e.g., visiting professorships or academic grand rounds).

Process for Requesting Approval of Industry-Paid Speaking Engagements:

  1. Obtain speaking contract or agreement in Word format from the Pharmaceutical Company.
  2. Complete the Industry Talk Approval Form, and attach the contract within the form. Note: the Industry Talk Approval Committee will not approve a request if the industry contract for the speaking engagement is not included with the request. 

SOM Approval Process

  1. The industry contract may first be reviewed by UPI legal counsel and, if necessary, revised to satisfy University policies.
  2. Note that the following language, which has been approved by the Industry Talk Approval Committee, must be included in all speaking contracts:

    "With regard to any presentation delivered by Speaker at the request of the Company pursuant to this Agreement, Speaker will have exclusive control over the content of any such presentation, including any accompanying presentation materials, handouts, or slides, based on Speaker's expertise and independent, objective professional judgment. The content of such presentations, including any accompanying materials, handouts, or slides, will not be subject to the review or approval of the Company, except that the Company may review handouts, slides and other materials for the sole purpose of ensuring compliance with FDA regulations. In additional, any such presentation will be for the purpose of providing information of general scientific interest and concern, and will not be focused on the marketing and promotion of the Company's products."

  3. If the contract is revised by legal counsel, it will be returned to the faculty member, and it is the faculty member's responsibility to gain approval of the revised language from the Pharmaceutical Company.  The speaking request will not be reviewed by the Industry Talk Approval Committee until the revised contract is approved by the Pharmaceutical Company and resubmitted to the Committee.

  4. Once Committee has received a finalized contract and speaker request, they will review the request and respond to faculty member within 10 business days.

Direct any questions to Cheryl Welch. 

Other important policies and documents:

​The Rules of the School of Medicine provide information specific to the organization of the School of Medicine, the School's departments, divisions and committees, and the policies that govern faculty appointments, promotions and tenure and were updated July 1, 2016.
The Unversity of Colorado is governed by an elected Board of Regents, which has created several documents which define the Board's work and the governance of the University.  Those documents include Laws of the RegentsRegent Policies, and Administrative Policy Statements.

The Faculty Handbook is an on-line reference that outlines many different laws, policies and procedures specific to University faculty.