Conflict of Interest Review Process

Prior to entering into a purchase contract with (or making a purchase from) a vendor with a prohibited or potential conflict of interest, the University of Illinois System must complete the following conflict of interest review process to determine whether the purchase is allowed under the Procurement Code.

Purchases from a vendor with a prohibited or potential conflict are prohibited on university Purchasing Cards (PCards) and Travel Cards (T-Cards).

All proposed procurements subject to the Illinois Procurement Code (30 ILCS 500/) that present prohibited conflicts or potential conflicts of interest are thoughtfully considered by the University of Illinois System and reviewed by independent state authorities as required by the Illinois Procurement Code. (30 ILCS 500/50-35(d))

The University of Illinois System does not have the final authority to determine whether a conflict of interest exists or whether a proposed purchase that presents a conflict may proceed. When a potential conflict of interest is identified, the appropriate university Purchasing and Contract Management Office or, for System units, System Purchasing and Support Services, must complete a Conflict of Interest Review and Determination form that describes the circumstances of the potential conflict along with the university’s justification for proceeding with the purchase.

Conflict of interest review requests involving vendors that have not undergone a review within the fiscal year must be considered by the respective state purchasing officer (SPO) and the Illinois Procurement Policy Board (PPB). The SPO also may refer the review request to the Chief Procurement Officer (CPO) prior to submission to the PPB for final review. The SPO may complete the review request without PPB approval if it involves a vendor that has undergone a review within the fiscal year or if the purchase is less than $100,000.

The University of Illinois System will cooperate with the review process conducted by the PPB and the Executive Ethics Commission as defined in the Procurement Code & Rules.

The University of Illinois System may not proceed with the procurement until:

• the PPB has completed a review of the potential conflict of interest review and authorizes the System to proceed;
• the SPO has completed a review of the potential conflict of interest review (when a review has previously been completed within the same fiscal year) and authorizes the System to proceed; or,
• after the PPB has sent communication indicating that they find the potential conflict to be an actual conflict, the EEC has held a hearing, and the EEC authorizes the System to proceed.

Forms Used in this Procedure

Conflict of Interest Review and Determination Form

Additional Resources

Illinois Administrative Code
Illinois Procurement Gateway
Purchase Order Hold Process

First Published: July 2017 | Last Updated: May 2023 | Last Reviewed: May 2023