Though University of Louisville’s institutional officers are required to annually fill out an Attestation and Disclosure Form — disclosing business interests and possible conflicts of interest — university records show President James Ramsey had not done so for three years, until the day after Insider Louisville submitted an open records request for that form in December.
Additional records received from the university show Ramsey did fill out a separate conflict of interest form last year for the University of Louisville Foundation — the university’s $1.1 billion nonprofit that he also leads — in which he did not disclose the same interests that he did in the December form. And although IL’s request for any conflict disclosure forms dated back to the beginning of 2013, the university did not turn over a nearly identical form Ramsey filled out for the U of L Board of Trustees in 2014 — which IL obtained independently of school officials — showing he disclosed no potential conflicts.
According to Sherri Pawson, the university’s senior compliance officer, Ramsey filled out his Attestation and Disclosure Form on Dec. 22, the day after IL requested any conflict disclosure statements submitted in the last three years by Ramsey and Dr. David Dunn — the executive vice president for health affairs, who is on leave from the university while being investigated by the FBI.
According to The Courier-Journal, Dunn, along with a current and former school employee, are being investigated over their for-profit company Health DataStream, which they allegedly operated out of the university. While Health DataStream has since been dissolved, it was still in operation when Dunn completed his ADF in 2013, and he did not disclose his affiliation with the company in that form.
Though incorporated in Delaware, Health DataStream’s address was listed as U of L’s Abell Administration Center, and the Foundation once considered buying a stake in the company, though the deal did not go through. Former Trustee Steve Wilson emailed former board chair Bob Hughes in September of 2014 to share that he heard the university was paying the company for services, though Hughes told the C-J these were “dated” rumors and the investigation of Dunn had already begun.
Ramsey’s ADF completed in December lists his affiliation with Texas Roadhouse, where he has served on the board of directors since 2004 and owns well over $3 million in stock. In 2010, U of L opened its $200,000 Texas Roadhouse Student Center at the College of Business, a lounge complete with the restaurant’s signage and branding. In the same form, Ramsey also disclosed that he is on the Advisory Board of LG&E, is affiliated with the U of L Foundation and the U of L Research Foundation’s Advanced Cancer Therapeutics companies, and receives gift cards or certificates from MPC Promotions, though the dollar amount was redacted.
Ramsey did not disclose on this ADF that he is on the board of a large investment firm — alternately named the Aquila Churchill Tax-Free Fund of Kentucky and the Aquila Narragansett Tax-Free Fund — nor did he disclose being on the board of Community Trust Bank.
On Ramsey’s separate conflict of interest statement filled out for the Foundation in 2015, Ramsey only listed his affiliation with the Advanced Cancer Therapeutics companies. In the 2014 conflict of interest statement he filled out in 2014 for the Board of Trustees — which the university failed to submit to IL — he listed no affiliations, and said he has no connection with any entity that does business with U of L. On both forms, Ramsey disclosed that his wife receives $12,000 annually for a car allowance.
Ramsey did not respond to questions asking why he waited until the day after the request from IL to fill out the ADF, why did he not list various affiliations in his conflict disclosure to the Foundation and Board of Trustees, and if the incomplete forms for himself and Dunn show that university leadership is not taking conflict disclosures seriously enough.
U of L Board of Trustees Chair Larry Benz told IL he is not aware of disclosure and conflict of interest policies outside of his board, saying “I can only answer regarding the controls and processes that are place since last summer and fall when I became Chair and inquired into the rigor and discipline of our disclosure and conflict policies, process, and compliance. Under the leadership and direction of Leslie Strohm, our general counsel, the practices and policies are sound, consistent, and compliance rates are well above best practices.”
***** UPDATE 8:20 p.m. *****
University spokesman John Karman responded in an email that Dr. Ramsey had previously not filled out an ADF form because he informed the Board of Trustees of any potential conflicts through their conflict of interest form. He also added that Ramsey’s conflict of interest form for the Foundation “does not include various business associations because it does not specifically ask for them. The ADF does.”
The nearly identical forms for the Foundation and Board of Trustees asks if the employee serves “as an officer, director or key employee of an entity” that does business with the university or the Foundation, or if they are a shareholder with at least a 5 percent ownership interest in such a business.