New ROA pre-approval requests must be submitted using PERA’s Conflict of Interest/Conflict of Commitment Module.
Questions about PERA may be directed to the PERA Help Team at perahelp@purdue.edu.Questions about the ROA policy may be directed to compliance@purdue.edu.
NOTE: If you have received a Notice to Update Disclosure Profile by email from PERA, you need to update your Disclosure Profile if you are still employed by Purdue. If you are no longer employed by Purdue, contact compliance@purdue.edu. Otherwise, you must complete this process EVEN IF
Extensive instruction materials, including step-by-step written instructions and click-by-click videos, are available here: Conflict of Interest – Purdue Excellence in Research Administration
Capitalized terms are defined in the policy. Please refer to the Definitions section.
Q 1. What is a Conflict of Commitment?
Q 2. What is a Reportable Outside Activity?
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.
The terms include, but are not limited to:
Note: there are some activities that are not Reportable Outside Activities UNLESS compensation is involved and/or a Foreign Adversary Entity is involved. See below for specific examples.
Reportable Outside Activity and Reportable Outside Activities do not include:
Q 3. Who is required to submit the Reportable Outside Activity Request?
All Exempt Employees are required to submit ROA requests and receive approval before engaging in the activity that is the subject of the request. The term Exempt Employee is defined as an employee of Purdue, wherever located, and whether full-time or part-time, including but not limited to all executive officers, faculty and exempt staff, and graduate student employees, including those on leave of absence with or without pay, who are exempt from the requirements of the Fair Labor Standards Act.
Nonexempt staff members (paid hourly), including police, fire, and skilled trade positions: These individuals are required to submit a request and receive approval 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 when the activity includes involvement with a Foreign Talent Recruitment Program.
Q 4. What are the responsibilities of Exempt Employees under the Conflicts of Commitment and Reportable Outside Activities policy?gs that are expected of me by my supervisor. Do I have to submit the disclosure?
Q 5. 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 Request?
If you are a faculty or exempt staff member, yes, the ROA Request must be submitted.
If you are a nonexempt staff member, you only need to submit the Request if the activity could potentially interfere with your University duties (see answer to question 3).
Q 6. If I am not sure whether I need to submit a Reportable Outside Activity Pre-Approval Request, who is the contact for clarification?
You may contact the Outside Activity Officer or the Vice President for Ethics and Compliance. Send inquiries to compliance@purdue.edu.
Q 7. Where do I submit the Reportable Outside Activity Pre-Approval Requests?
Since August 2025, Reportable Outside Activity requests are submitted in the Purdue Excellence in Research Administration Conflict of Interest/Conflict of Commitment Module [“PERA COI/COC Module”].
When you land on the Purdue Excellence in Research Administration site (pera.research.purdue.edu), scroll down and click on the Conflict of Interest / Conflict of Commitment Module tile.
Q 8. When do I have to file the Reportable Outside Activity Request?
Q 9. I completed a Reportable Outside Activity Pre-Approval Request last year, and it was approved. Why do I have to complete the Request again?
Reportable Outside Activities must be approved on an annual basis in order to ensure that a Conflict of Commitment doesnot arise due to a change in your other outside activities, other issues involving your responsibilities to the University, and to insure compliance with other University policies and missions.
Q 10. If the circumstances of a Reportable Outside Activity change after I receive permission to engage in it, do I need to do anything?
Yes, you must submit a new request that describes the change and receive permission before continuing to engage in the activity.
Q 11. If I don’t file a Reportable Outside Activity Pre-Approval Request and engage in an outside activity, what are the consequences?
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.
Q 12. How is Consulting defined?
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.
Q 13. Does this policy prohibit me from being a paid consultant for a corporation or for-profit company?
No. Consulting is not prohibited as long as it does not present a Conflict of Commitment.
Before serving as a consultant, you must submit a Reportable Outside Activity request and receive approval before beginning the work.
Q 14. I am a tenured professor at Purdue, and I consult for several companies. Is there a time limitation on Consulting?
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. NOTE: the availability of one business day per week is limited to tenured and tenure track faculty members. Clinical faculty and research faculty do not have one business day per week for Reportable Outside Activities.
Q 15. I am co-founder of a company, but I do not have any income from this relationship yet. Is this a Reportable Outside Activity?
Yes. Participation as an owner or partner in a business enterprise must be reported.
Q 16. 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?
Due to receipt of compensation a Reportable Outside Activity request should be submitted in advance of completing such a survey.
Q 17. May I take an honorarium for giving a lecture?
If you submit a Reportable Outside Activity request in advance of the lecture and receipt of the honorarium and receive approval, yes.
If you are an investigator on a sponsored project, the honoraria may need to be disclosed under the Individual Financial Conflicts of Interest policy.
Q 18. If I receive royalties or compensation for publishing works, is this a Reportable Outside Activity?
Yes. 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 19. 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.
Q 20. How does this policy work in relation to sabbatical?
If the activities a faculty member will engage in during sabbatical are Reportable Outside Activities, then a ROA request must be submitted and approved in advance. Faculty must also comply with the requirements of Sabbatical Leaves (I.A.5)
Q 21. 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 Request for this activity?
Yes. Participation in professional associations does not need to be reported, but service as an officer does.
Q 22. What if I don’t agree with the conditions of a management plan?
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.
Q 23. My Reportable Outside Activity Request was denied. Can I appeal?
Yes. If you disagree with a determination regarding a request to engage in a Reportable Outside Activity, 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. See Operating Procedures for Reportable Outside Activity Requests.
Q 24. I am an Exempt Employee, but my consulting is strictly limited to nights and weekends. Do I need to report it?
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.
Q 25. As an academic-year employee, do I need to report activity that occurs during the summer?
Yes, Exempt Employees who are employed on an academic-year basis including faculty members and graduate student employees must submit a request and receive permission before engaging in a Reportable Outside Activity during the summer. Summer activities have the potential to present a Conflict of Commitment.
Q 26. I’m a part-time employee. Do I need to report my other job?
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. This includes Limited Term Lecturers.
Q 27. 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?
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 must be disclosed.
Q 28. 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?
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 must be disclosed. Because you still have an ownership interest in the LLC – even years where no consulting activity takes place — the ownership interest must be disclosed.
Q 29. I’m a faculty member, and I do my consulting work through an LLC. Do I need to disclose each of the entities for whom the consulting work is performed?
Yes. The University needs to know the name of each entity 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).
Purdue addresses must not be used as your principal place of business in filings with state secretaries of state, tax returns, or any other purpose.
Q 30. Am I able to use University facilities, equipment, and resources for an approved ROA?
No. You cannot use University facilities, equipment, and resources for an approved ROA unless you have a specific contract approved. This prohibition includes your Purdue issued computer, Purdue IT resources including email, software, and your University office and/or work space, labs, and Purdue name and address.
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)).
Q 31. I’m a faculty member. Occasionally, I have the department administrative assistant perform clerical work during her Purdue work day for my consulting work through my LLC. Is this allowable?
No. This is a violation of Indiana criminal law for you as the supervisor as well as for the administrative assistant.
Q 32. The Conflicts of Commitment and Reportable Outside Activities (III.B.1) policy contains a provision regarding the preparation and publication of scholarly publications, i.e., books, articles, and other creative works. Although such activities are usually not ROAs, if a Foreign Adversary Entity (1) provides compensation for and/or (2) is involved as a publisher, co-author, co-editor, or some other role in the preparation and publication of scholarly communications, the activity is a Reportable Outside Activity that must be disclosed. What is a Foreign Adversary Entity?
For purposes of disclosures of ROAs, the term “Foreign Adversary Entity” means a business, governmental entity, or other entity (or any of their agents, trustees, or fiduciaries) organized under the laws of, headquartered in, or owned or controlled by citizens or the government of a Foreign Adversary Nation. Currently, China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela are Foreign Adversary Nations.
Authors are not required to submit a ROA Pre-Approval Request for scholarly publications unless a Foreign Adversary Entity provides compensation and/or is involved as a publisher, co-author, or some other role in the preparation and publication of scholarly communications.
Q 33. How do I submit a Pre-Approval Request of a Reportable Outside Activity for the exceptions described in Q31?
To disclose that a Foreign Adversary Entity (1) provides compensation for and/or (2) is involved as a publisher, co-author, or some other role in the preparation and publication of scholarly communications:
Step-by-step directions are available for specific request types, including “Research and Collaboration Including Co-Authors” at this link:
COI 3 – ROA Pre-Approval Request – Purdue Excellence in Research Administration
Q 34. What am I required to do if one or more of my co-authors is from a different country? What if I know that a co-author lives in a Foreign Adversary Nation, but I do not where they are employed or registered as a student? What am I required to do if one of the contributors writing a chapter for a book I am editing is originally from a Foreign Adversary Nation but now is a faculty member at a university in a country that is NOT a Foreign Adversary Nation ? Am I required to submit a pre-approval request if the publisher is located in the United States?
The policy on Conflicts of Commitment and Reportable Outside Activities (III.B.1) does not require a ROA Pre-Approval Request based upon a person’s nationality. The requirement for a ROA Pre-Approval Request is triggered by the co-author’s affiliation with a Foreign Adversary Entity. For example, if a co-author is a U.S. citizen and is employed at a university in located in a Foreign Adversary Nation, an Request would be required. Similarly, if a co-author is originally from one of the Foreign Adversary Nations but is now a faculty member with a university in another country that is not a Foreign Adversary Nation, there is no requirement to submit a ROA Pre-Approval Request. There is no requirement to submit a pre-approval request for U.S. publishers. However, if your contract is with a U.S. branch or subsidiary of a publisher located in a Foreign Adversary Nation, you are required to submit an ROA Pre-Approval Request.
Q. 35 When should I submit a ROA Pre-Approval Request if a Foreign Adversary Entity is providing compensation and/or one of my co-authors is affiliated with (employed by or a student with) a Foreign Adversary Entity?
Like all other ROA Pre-Approval Requests under the policy on Conflicts of Commitment and Reportable Outside Activities, the ROA should be submitted before a faculty member signs a contract for a book or engages in collaborative research with someone affiliated with a Foreign Adversary Entity.
Q. 36 If I have an approved ROA Pre-Approval Request for Research and Collaboration Including Co-Authors, am I allowed to use University facilities such as libraries, my office, and University owned equipment like my University-issued laptop?
Preparation and publication of scholarly communications are expected duties of faculty members. These activities are not Reportable Outside Activities unless a Foreign Adversary Entity provides compensation and/or is involved as a publisher, co-author, or some other role in the preparation and publication of scholarly communications. If the ROA Pre-Approval Request for Research and Collaboration Including Co-Authors is approved, the prohibition on use of University facilities and equipment does not apply.
Q. 37 I just received an email from NoReplyPeraNotification@purdue.edu that says I need to update my Disclosure Profile. What does that mean?
The policy on Conflicts of Commitment and Reportable Outside Activities requires that all Exempt Employees complete training on the policy and to certify on an annual basis that they have either disclosed all of their Reportable Outside Activities OR that they have no Reportable Outside Activities to disclose.
Updating your Disclosure Profile in the PERA COI/COC module will provide the opportunity to
When you successfully update your Disclosure Profile, the words “Action Required” will change to “No Action Required.” The language in the Instruction Center box will also change to reflect completion. Finally, you will receive an email notification from PERA that you have successfully updated your Disclosure Profile.
Q. 38 My Reportable Outside Activity Pre-Approval Request includes international travel to a Foreign Adversary Nation. When should I submit the ROA Pre-Approval Request in PERA?
The best practice is to submit your request as far in advance as possible. You should allow at least two (2) months for your request to be reviewed. If you plan to travel at a peak time, try to submit your request 3 to 4 months before your desired travel.
Q. 39 I submitted a ROA Pre-Approval Request that involves international travel, and it is still “under review.” The conference I plan to attend is only a few weeks away. What should I do?
Keeping in mind that the Conflicts of Commitment and Reportable Outside Activities policy requires receiving approval before engaging in a Reportable Outside Activity, you should not go without receiving approval. Contact the office or person who is listed as the Assigned Reviewer and ask for assistance. If the Assigned Reviewer field is empty, contact compliance@purdue.edu or submit a PERA Support ticket on this site: PERA Help – Purdue Excellence in Research Administration or email perahelp@purdue.edu.
Q 40. Is running for a political office an activity that requires disclosure?
Yes. The University has long recognized that faculty and staff have a duty and right as citizens to participate in the political processes of society. Any employee seeking to hold a part-time political office must seek prior approval to engage in the activity. Any employee who accepts or seeks a full-time office must obtain a leave of absence for the period of service or resign from the University. For specific details on running for political office, see the policy on Political Activities (III.B.4).