FAQs Regarding the Conflict of Commitment and Reportable Outside Activities Policy
Capitalized terms are defined in the policy. Please refer to the Definitions section.
- What is a Conflict of Commitment?
- What is a Reportable Outside Activity?
- What activities do NOT need to be approved in advance?
- Who is required to submit the Reportable Outside Activity Form?
- What are some examples of exempt employees?
- Several of the examples included in the definition of a Reportable Outside Activity are things that are expected of me by my supervisor. Do I have to submit the form?
- If I am not sure whether I need to submit a Reportable Outside Activity Form, who is the contact for clarification?
- When do I have to file the Reportable Outside Activity Form?
- Where do I find the Reportable Outside Activity Form?
- I submitted my Reportable Outside Activity Form; when can I expect to receive a response?
- I completed a Reportable Outside Activity Form last year. Why do I have to complete the form again?
- If the circumstances of a Reportable Outside Activity change after I receive permission to engage in it, do I need to do anything?
- If I don’t file a Reportable Outside Activity Form and engage in an outside activity, what are the consequences?
- How is Consulting defined?
- Does this policy prohibit me from being a paid consultant for a corporation or for-profit company?
- I am a tenured professor at Purdue, and I consult for several companies. Is there a time limitation on Consulting?
- I provide advice for a company and don't receive compensation, but I am reimbursed for travel expenses. Does that constitute Consulting?
- I am co-founder of a company, but I do not have any income from this relationship yet. Is this a Reportable Outside Activity?
- As a scientist, I am asked to participate in online surveys relative to my area of expertise. I am paid a small amount of money for this activity. Is this a Conflict of Commitment?
- May I take an honorarium for giving a lecture? Can I accept honoraria from industry?
- If I receive royalties or compensation for publishing works, is this a Reportable Outside Activity?
- I am a faculty member, and I am actively involved in a professional association related to my University duties. Is the work I perform for the association, including attendance at quarterly meetings, considered a Reportable Outside Activity?
- How does this policy work in relation to sabbatical?
- I am an officer of a professional association, and my participation is necessary to maintain a license required for my job. Do I have to submit a Reportable Outside Activity Form for this activity?
- What if I don't agree with the conditions of a management plan?
- My Reportable Outside Activity Form was denied. Can I appeal?
- I am an exempt employee, but my consulting is strictly limited to nights and weekends. Do I need to report it?
- As an academic-year employee, do I need to report activity that occurs during the summer?
- I'm a part-time employee. Do I need to report my other job?
- I am a member of a family LLC. The LLC owns our family farm and a house that is rented. Do I need to report the LLC as a Reportable Outside Activity?
- I'm a faculty member, and I engage in consulting. I have an LLC for my consulting activities. Do I need to disclose the LLC in years when I don't do any consulting?
- I'm a faculty member, and I do my consulting work through an LLC. Do I need to disclose the entities for whom the consulting work is performed?
- Am I able to use University facilities, equipment, and resources for an approved ROA?
A Conflict of Commitment is defined as a situation in which:
- An employee's Reportable Outside Activities would likely interfere with the employee's ability to fulfill their commitment to the University; or
- An employee's responsibilities, financial interest or opportunity for personal benefit in connection with a Reportable Outside Activity would likely interfere with the employee's professional judgment in exercising any University duty or responsibility.
A Reportable Outside Activity is defined as any work, advice or service for an entity other than Purdue University that may potentially result in a Conflict of Commitment.
Below is a list of examples:
- Participation in any business enterprise as owner, partner, officer, supervisor, manager or in any capacity with management responsibilities
- Service as an officer, director, trustee or public representative of a professional association, educational institution, nonprofit organization, national commission or board, or foundation
- Consulting (as defined in the policy)
- Having responsibility for any course at, or representing oneself as a faculty member at, any other school or university
- Conducting external research that would not ordinary be conducted as a part of the employee's duties with the University
- Service on an advisory council or scientific advisory board of a company or organization other than a state or federal agency
- Volunteer work that involves a commitment of time that may interfere with the employee's ability to fulfill their responsibilities to the University
- For exempt employees, including faculty members, any other employment with or service to an outside entity where compensation in the form of money, services, goods or other consideration of value is received
You do not need to submit a Reportable Outside Activity Form for the following activities:
Volunteer work that does not interfere with the Employee’s ability to fulfill their responsibilities to the University (e.g., volunteer work that takes place on Saturday or Sunday or outside of the regular business or instructional hours of the University generally will not pose a Conflict of Commitment.
Hobbies or recreational activities
Preparing and publishing scholarly communications such as books, articles and other creative works
Peer review of manuscripts and grant proposals
Editing of scholarly or professional publications or service on editorial boards for scholarly or professional publications
Service without compensation, or with honoraria less than $1,000 annually, 1) on U.S. federal or state government agencies and boards, 2) on U.S. federal or state granting agency peer-group review panels, 3) on advisory groups for other U.S. universities or 4) in similar capacities primarily for the purpose of providing a public or University service within the United States
- All faculty and exempt staff, whether part time or full time: These individuals are required to submit a form before they engage in any Reportable Outside Activity.
- Nonexempt staff members (paid hourly), including police, fire, and skilled trade positions: These individuals are required to submit a form before engaging in a Reportable Outside Activity that may interfere with their normal University responsibilities, that will take place during the employee’s normal work hours, or if the employee has an ownership interest in a business or is employed by a business that provides goods and/or services to the University. Additionally disclosures and approvals for these business interests will be required under the policy Individual Financial Conflicts of Interest (III.B.2). Outside employment or activities that take place during off hours or during leave time will, in most cases, not divert attention from University duties and do not need to be submitted on a Reportable Outside Activity form..
Exempt employees include tenure and tenure-track faculty; clinical faculty; research faculty; lecturers and limited-term lecturers; instructors: executive, management and professional staff members: and graduate student staff members. Typically, anyone who is not paid by the hour is considered an exempt employee.
If you are a faculty or exempt staff member, yes, the form must be submitted.
If you are a nonexempt staff member, you only need to submit the form if the activity could potentially interfere with your University duties (see answer to question 4).
Many Reportable Outside Activities, in and of themselves, will not present a Conflict of Commitment, and your Unit Head will be able to approve the activity. But the particulars of the activity must be considered relative to any other activities you are engaged in and your responsibilities at the University.
You can contact your Unit Head, the Outside Activity Officer, or the Vice President for Ethics and Compliance.
- New Activities: You must file the form before you engage in any new Reportable Outside Activity.
- Continuing Activities: At the beginning of each fiscal year you must file a Reportable Outside Activity Form for all activities in which you continue to participate, even if previous permission was granted.
- Changed Activities: If the scope or nature of a Reportable Outside Activity changes after permission has been granted, you must file a new form before you can continue to engage in the changed activity.
Your Unit Head has 10 business days to make a determination. You will receive an email from "ROA Administrator" to let you know what the decision for each activity is.
If your Unit Head cannot determine whether the Reportable Outside Activity you submitted will give rise to a Conflict of Commitment, your form will be forwarded to the OA Officer, who will evaluate the request and help your Unit Head make a decision.
Reportable Outside Activities must be approved on an annual basis in order to ensure that a Conflict of Commitment doesn’t arise due to a change in either your other outside activities or your responsibilities to the University.
Yes, you must submit a new form before continuing to engage in the activity.
Disciplinary action for violating the policy will vary depending on the extent of the violation and may range from a warning to termination of employment.
Consulting is an employee's use of their professional capabilities and knowledge for the benefit of a third party in return for immediate or prospective gain.
Consulting generally is not:
- Service without compensation, or with honoraria less than $1,000 annually;
- Service primarily for the purpose of providing a public or university service (e.g., on U.S. governmental agencies and boards, on U.S. granting agency peer-group review panels, on advisory groups for other U.S. universities)
Consulting by tenured and tenure-track faculty is not prohibited as long as it does not present a Conflict of Commitment or exceed, on the average, one business day per week when combined with all other Reportable Outside Activities.
Before serving as a consultant, you must submit a Reportable Outside Activity Form for approval.
Consulting by tenure and tenure-track faculty members generally may not exceed, on the average, one business day per week during the term of appointment when combined with all other Reportable Outside Activities.
Service without compensation or honoraria less than $1,000 does not qualify as Consulting and does not need to be reported as a Reportable Outside Activity. Travel reimbursement is not compensation, but in some circumstances, reimbursement of travel expenses may constitute a Conflict of Financial Interest. Refer to the policy on Individual Financial Conflicts of Interest (III.B.2).
Yes. Participation as an owner or partner in a business enterprise must be reported.
This would likely not be considered a Conflict of Commitment, but would be a Reportable Outside Activity because you are being compensated. Therefore, you must submit a Reportable Outside Activity Form.
Accepting minor honoraria for giving lectures is allowed, whether from academic organizations or industry. If the honorarium is more than $1,000 annually, a Reportable Outside Activities Form must be submitted prior to engaging in the activity.
If you are an investigator on a sponsored project, the honoraria (of any amount) may need to be disclosed under the Individual Financial Conflicts of Interest policy.
Work on scholarly publications does not need to be reported. If the publication is not a scholarly communication, then a Reportable Outside Activity Form must be submitted. Depending on your responsibilities to the University, the royalties or compensation may also need to be disclosed in accordance with the Individual Financial Conflicts of Interest policy.
Q 22. I am a faculty member, and I am actively involved in a professional association related to my University duties. Is the work I perform for the association, including attendance at quarterly meetings, considered a Reportable Outside Activity?
No. Only service as an officer, director, trustee or public representative for such organizations needs to be reported.
If the activities a faculty member will engage in during sabbatical are Reportable Outside Activities, then a form must be submitted in advance. Faculty must also comply with the requirements of Executive Memorandum No. B-11 (Sabbatical Leave of Absence).
Q 24. I am an officer of a professional association, and my participation is necessary to maintain a license required for my job. Do I have to submit a Reportable Outside Activity Form for this activity?
Yes. Participation in professional associations does not need to be reported, but service as an officer does.
You may appeal the conditions of a management plan in writing to the Vice President for Ethics and Compliance (VPEC) within 10 days of the determination. The VPEC will convene a committee to review the appeal, and the committee's decision on the matter is final.
Yes. If you disagree with a determination regarding a request to engage in Reportable Outside Activities you may submit a written appeal to the Vice President for Ethics and Compliance (VPEC) within 10 days of the determination. The VPEC will convene a committee to review the appeal, and the committee's decision on the matter will be final.
Yes. All Reportable Outside Activity by exempt employees needs to be reported regardless of when it takes place. The only exception based on the time of the Activity is for volunteering outside of normal business hours.
Yes, exempt academic-year employees must submit a disclosure. Summer activities have the potential to present a Conflict of Commitment.
Yes, if you are an exempt employee at Purdue. Part-time employees are expected to devote their professional or occupational time and energy in accordance with their agreed upon commitments.
Yes. Participation in any business enterprise as an owner, partner, officer, supervisor, manager or in any capacity with management responsibilities is a Reportable Outside Activity that needs to be disclosed.
Yes. Participation in any business enterprise as an owner, partner, officer, supervisor, manager or in any capacity with management responsibilities is a Reportable Outside Activity that needs to be disclosed. Because you still have an ownership interest in the LLC – even years where no consulting activity takes place -- that should be disclosed.
Yes. The University needs to know the names of the entities for whom faculty and staff are doing work to appropriately address any Conflicts of Commitment and potential issues involving Individual Financial Conflicts of Interest (III.B.2).
No, you cannot use University facilities, equipment, and resources for an approved ROA unless you have a specific contract approved.
Per IV.B.1 - University Policy Office - Purdue University: University Facilities may be used only by persons authorized by the CFO on the West Lafayette campus and by the Chancellors of the Regional Campuses (or their authorized representative) and only in the manner and for purposes authorized by the CFO or Chancellor. Regular, recurring use of a University Facility by a non-University entity and/or for private business use is permitted only by terms of a separate, specific contract approved by the CFO, Chancellor or authorized representative (see Third-Party Use of Facilities (S-2)).