Policies, Responsibilities, and Procedures
Review of Consulting Businesses
Review of Consulting Businesses
Consulting businesses established by the unclassified staff are assigned for review by a COI Committee member based on the criterion of ownership in a privately held entity. If the privately held entity appears to be a consulting only business, the reviewer should determine if the following conditions apply:
- Solely owned by the individual;
- No other employees; and
- The assets or value of the entity come from only consulting work.
If all three conditions are true, the reviewer should recommend “no management, LLC letter” for the entity. Upon this approval, the COI Office will send a letter to the investigator with instructions stating that if the entity enters into a consulting agreement with an individual client with compensation greater than $5,000 that has not already been disclosed, then the individual must update his or her OAR to disclose this client as a separate entity. The COI Committee will review entities disclosed in response to this letter based on the existing review criteria.
If the COI Committee reviewer determines one or more of the three conditions described above are not true, and that a nexus exists between the consulting business and the individual’s institutional responsibilities, then the reviewer should recommend management for the entity.