Operating Procedures for Reportable Outside Activity Requests

Effective date: December 19, 2025

Notice

Prior to the beginning of each fiscal year, the VPEC will remind all Exempt Employees of their obligation to submit a Reportable Outside Activity pre-approval request in the PERA Conflict of Interest/Conflict of Commitment (COI/COC) module prior to engaging in a new Reportable Outside Activity and annually thereafter. The VPEC will publish additional reminders in January and August.

Annual Training and Certification of Compliance

Exempt Employees are required to update their disclosure profile in the PERA COI/COC module by the deadline specified in the annual email notice. This includes completion of training on policy III.B.1, certification of compliance with policy III.B.1, and submission of any Reportable Outside Activity pre-approval requests.

When to Submit a Reportable Outside Activity Form

Employees must submit a Reportable Outside Activity pre-approval request:

1. For each new Reportable Outside Activity, prior to engaging in the activity,
2. On an annual basis, in accordance with deadlines specified by the VPEC, for each continuing Reportable Outside Activity, and
3. When the scope or nature of a previously approved Reportable Outside Activity changes.

Review of Reportable Outside Activities

1. Upon receipt of a pre-approval request, the Unit Head (referred to in the PERA COI/COC module as a division head) or their designee will promptly:
   1. Determine whether the Reportable Outside Activity will result in a Conflict of Commitment or will otherwise violate policy III.B.1 or any other University policy,
   2. Seek clarification from the employee, if needed,
   3. Approve or deny the disclosed Reportable Outside Activity or assign the OA Officer as a reviewer if unable to make a determination.
2. Unit Heads, designees and the OA Officer may not grant permission for an employee to engage in a Reportable Outside Activity that will result in a Conflict of Commitment or that otherwise violates policy III.B.1. This includes participation in or affiliation with a Foreign Talent Recruitment Program that is deemed malign or is otherwise prohibited. Unit Heads may consult at any time with the OA Officer for assistance in interpreting and implementing these procedures and in deciding if a particular Reportable Outside Activity will or may result in a Conflict of Commitment.
3. Upon receiving a Reportable Outside Activity pre-approval request, the OA Officer promptly will evaluate the request to determine if the proposed Reportable Outside Activity, by itself or in conjunction with any of the employee’s other approved Reportable Outside Activities, would result in a Conflict of Commitment or otherwise violate policy III.B.1. The OA Officer may:
   1. Request that the employee provide the OA Officer with clarification  to assist in evaluating the request,
   2. Consult with the Unit Head, the employee and any other person that the OA Officer deems appropriate to consult, and
   3. Condition permission to engage in a Reportable Outside Activity on the employee’s acceptance of a management plan to limit participation in the activity within stated parameters. The OA Officer will upload  any  management plan in the PERA COI/COC module.
4. The OA Officer will  promptly enter the decision to grant, deny or impose conditions on an employee’s pre-approval request to engage in a Reportable Outside Activity in the PERA COI/COC module. 

Review of Disclosures by the President

A Reportable Outside Activity disclosure submitted by the President will be reviewed by the chairperson of the Board of Trustees with the advice and assistance of the VPEC. The chairperson may consult with the rest of the Board of Trustees or any person deemed appropriate in order to determine if the requested Reportable Outside Activity would create a Conflict of Commitment. The chairperson may grant or deny the President’s request or condition permission on an agreement by the President to limit participation in such activity within stated parameters. Written notice of the decision will be provided to the President.

Monitoring of Reportable Outside Activities

Each Unit Head is responsible for monitoring approved Reportable Outside Activities to make sure they have not developed over time into Conflicts of Commitment or other violations of policy III.B.1 or any other University policy. If at any time previously granted permission for an employee to engage in a Reportable Outside Activity is withdrawn, the employee must stop engaging in the activity.

Appeals

1. An employee may submit a written appeal to the VPEC within 10 days of receiving a determination to deny a request to engage in a Reportable Outside Activity or to impose conditions or restrictions limiting participation in an activity. The VPEC will appoint and chair an ad hoc appeals committee to review and render a decision on the matter, which will be final for all purposes. The committee will generally render its decision within 15 days of meeting to consider the written appeal.
2. The President may appeal a decision by the chairperson of the Board of Trustees to the Board of Trustees, whose decision regarding the matter will be final for all purposes.

Auditing

The OA Officer will audit Reportable Outside Activities approved for employees to ensure compliance with policy III.B.1 and these procedures.

History and Updates

December 19, 2025: Updated to reflect implementation of processes in the PERA COI/COC module.

January 8, 2024: Added to annual notice the requirement that Employees certify compliance. Section III updated to address disclosures of Foreign Talent Recruitment Programs.

January 1, 2019: Procedures separated from the policy on Conflicts of Commitment and Reportable Outside Activities (III.B.1). Updates to the procedures include eliminating sending paper copies of forms to Human Resources, appointing an ad hoc committee to review appeals rather than having a standing committee and replacing annual reporting with auditing.