Reportable Outside Activity Form Guidelines
In accordance with Purdue University's policy on Conflicts of Commitment and Reportable Outside Activities (III.B.1), no employee may engage in a Reportable Outside Activity until:
1) The employee has submitted the Reportable Outside Activity on a Reportable Outside Activity Form and
2) The Unit Head or OA Officer has given written approval for the employee's participation in the Reportable Outside Activity described in the form.
Instructions
The following instructions are provided to assist faculty and staff members in determining whether they have a Reportable Outside Activity and in completing the actual form. In addition, the guidelines provide department and unit heads with detailed instructions on how to complete a review.
Instructions for Faculty and Staff Members Who are Submitting the Reportable Outside Activity (ROA) Form
Q1. Who needs to submit the ROA Form?
Q2. When should an ROA Form be submitted?
Q4. What types of activities need to be reported?
Q5. What types of activities do not need to be reported?
Q6. When is consulting an activity that requires disclosure?
Q7. Is running for a political office an activity that requires disclosure?
Q8. How do I log in and submit a Reportable Outside Activity for review?
Q10. How do I explain how the days will be distributed?
Q12. Should I make a copy of the form for my records?
Q13. What if I submit a form in error?
Q14. How many forms should I submit?
Q16. Who gets my form?
Q17. How can I determine the status of my submission?
Q18. How long before I will get a response?
Q20. What if I have additional ROA questions?
Information for Department and Unit Heads Who Are Reviewing the Reportable Outside Activity (ROA) Form
Q21. How will I know I have something to review?
Q22. What if I am not receiving my seven-day email notifications?
Q23. How do I log in and conduct a review?
Q24. Should I make a copy of the form for my records?
Q25. What if I need more information?
Q26. What if a form was submitted in error?
Q27. Can a faculty or staff member see any of the comments I posted during my review?
Q28. What if I am leaving the University?
Q29. What if I have been incorrectly designated as a Department Head?
Q30. How will a new Department Head access outstanding submissions sent to a former Department Head?
Q31. Is there a way to observe all the current disclosures submitted to my area?
Q32. Is there a way to run a year-end spreadsheet of all outside activities submitted to my area?
Q33. How long do I have to respond?
Q34. Additional Department and Unit Head Questions
Instructions for Faculty and Staff Members Who are Submitting the Reportable Outside Activity (ROA) Form
Q1. Who needs to submit the ROA Form?
- 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 an ROA form.
Q2. When should an ROA Form be submitted?
Forms must be submitted prior to engaging in any new Reportable Outside Activity and at the beginning of each fiscal year, thereafter, even if it is a renewal of a previously approved activity. Such disclosures may be more frequent if the scope and/or nature of an existing outside activity is altered or approval of a new Reportable Outside Activity is being requested.
Q3. If the activity has been approved previously, do I need to include it again on a Reportable Outside Activity Form renewal?
Yes. At the start of a new Fiscal Year (July 1)
Example: Professor Smith wishes to perform consulting for ABC Corporation. The consulting runs from 3:00pm Sunday to 12:00pm Tuesday in each January, April, July, and September. After the fiscal year ends on June 30, Professor Smith should renew the ROA Form listing the July and September obligations.
Example: Professor Jones seeks permission to teach a summer class in Europe. The class will be 3 hours long and meet 3 days a week from June 15 through the beginning of August 7. After the fiscal year ends on June 30, Professor Jones should renew the ROA Form listing the July - August activity.
Q4. What types of activities need to be reported?
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 following are some examples:
- Participating in any business enterprise as owner, partner, officer, supervisor, manager or in any capacity with management responsibilities.
- Serving as an officer, director, trustee or public representative of a professional association, educational institution, nonprofit organization, national commission or board, or foundation.
- Acting as a consultant (as defined in the policy).
- Assuming responsibility for any course at, or representing oneself as a faculty member at, any other school or university.
- Conducting external research that would not ordinarily be conducted as a part of the employee's duties with the University.
- Serving on an advisory council or scientific advisory board of a company or organization other than a U.S. state or federal agency.
- Performing volunteer work that involves a commitment of time that may interfere with the employee's ability to fulfill their responsibilities to the University; performing volunteer work that takes place on Saturday or Sunday or outside the regular business or instructional hours of the University generally will not pose a Conflict of Commitment.
- Engaging in employment with or service to an outside entity where compensation in the form of money, services, goods or other consideration of value is received (applies to faculty and exempt employees).
Q5. What types of activities do not need to be reported?
Employees do not need to submit a Reportable Outside Activity Form for the following activities:
- Preparing and publishing scholarly communications, such as books, articles and other creative works.
- Reviewing, as a peer, manuscripts and grant proposals.
- Editing scholarly or professional publications or serving on editorial boards for such publications.
- Attending or presenting at events sponsored by professional organizations or academic institutions, such as professional meetings, workshops, colloquia, symposia, seminars or training programs.
- Visiting other sites in connection with accreditation, audits, sponsored project reviews or like activities.
- Participating in non-professional activities such as:
- Volunteer work that does not interfere with the employee's ability to fulfill their responsibilities to the University.
- Hobbies or recreational activities.
- Religious activities.
Q6. When is consulting an activity that requires disclosure?
Consulting is defined as 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 does not generally include service without compensation or with honoraria less than $1,000 annually. It also does not generally include the following: 1) serving on U.S. governmental agencies and boards, 2) serving on U.S. federal or state granting agency peer-group review panels, 3) serving on advisory groups for other U.S. universities, or 4) serving in similar capacities primarily for the purpose of providing a public or university service within the United States.
Q7. 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, seethe policy on Political Activities (III.B.4).
Q8. How do I log in and submit a Reportable Outside Activity for review?
- Go to the ROA Form at ecn.purdue.edu/VPEC/ROA.
- Log in by typing your Purdue Career Account username and password.
- Select the "My disclosures" tab.
- Select the "Submit a new form" button.
- Complete the form and provide any additional comments you feel are necessary for the Department Head and Unit Head to make an informed decision for each activity. Please note that the system limits you to 20 lines or 2000 characters in the comments box.
- Type your first name, middle initial and last name in the "Signed by" box. Please note: Inserting an electronic signature is prohibited by the system.
- Enter your password in the "Purdue Career Account Password" box.
- If your form is complete and ready to send, select the "Sign and submit for review" button. Select the "Save for later" button if you wish to come back to it for further review and completion.
- If you select the "Save for later" button, your saved form will appear as "Not submitted" on the "My outside activity disclosures" page. Click "Not submitted" link on the left-hand side of the page to continue editing, removing or submitting your form.
Q9. How do I complete the "total number of days" during academic year and summer portions of the Reportable Outside Activity Form?
For all activity types, list the number of calendar days (including weekends) during the period that you will engage in the activity for any portion of the day. The academic year and summer periods vary slightly from year to year, but the academic year typically runs from mid-August to mid-May.
Example: Professor Smith wishes to perform consulting for ABC Corporation. The consulting runs from Sunday to Tuesday in each January, April, July, and September. Professor Smith also expects to spend two days adjusting an existing presentation for this opportunity. Professor Smith should indicate “11 days” in the field requesting the total number of days during the academic year and “3 days” in the field requesting the total number of days during the summer. Professor Smith should submit a separate disclosure for each fiscal year in which she expects to engage in the consulting, i.e., one for the consulting in January and April and one for the next fiscal year for the activities in July and September.
Example: Professor Singh seeks permission to teach a summer class at the University of Cambridge in the United Kingdom. The class will be 3 hours long and meet 3 days a week from June 15 through August 7. Professor Singh should submit this request under category “E. Other Universities and Research Institutes.” The days per academic year would be “0." The days during the summer would be “24 days.”
Q10. How do I explain how the days will be distributed?
Explain if the activity will occur regularly (daily, weekly, monthly, etc.) or at particular times throughout the year. You may also list specific dates for irregularly occurring activities. You may use the Comment box to describe the time commitment in more detail.
Example: Professor Zhang has an academic year appointment. In September, he is contacted about consulting for ABC Corporation starting in October. The consulting runs from Sunday to Tuesday in each January, April, July, and October for three consecutive years. When Professor Zhang completes the form in September, he should indicate “3 consecutive days (Sunday through Tuesday) each month in October, January, and April” in the field requesting an explanation related to the academic year and “3 consecutive days (Sunday through Tuesday) in July” in the field requesting an explanation related to the summer. After the fiscal year ends on June 30, Professor Zhang should renew the ROA with the same information for the next academic year and the same information for the next summer. Professor Zhang should renew the ROA in the following fiscal year for the last year of the consulting relationship with ABC Corporation.
Example: Professor Jones seeks permission to teach a summer class in Europe. The class will be 3 hours long and meet 3 days a week from June 15 through the beginning of August 7. The days per academic year would be “0." The days during the summer would be “24 days.” After the fiscal year ends on June 30, Professor Jones should renew the form listing the previously approved activity.
Q11. If I am to be compensated with honoraria less than $1000 for the engagement, should I indicate that I am not being compensated?
Generally, if you are receiving any compensation, you should indicate that it you are being compensated. However, if you are receiving honoraria less than $1000, you should consider that the activity might not be a Reportable Outside Activity. Review the policy or see the enhanced list of Reportable Outside Activity frequently asked questions.
Q12. Should I retain a copy for my records?
Since you may choose to either save your document for later review and completion or submit it, you do not need to maintain a hard copy for your records. When you log in to the system, you will always be able to retrieve all of your past submissions.
Q13. What if I submit a form in error?
A faculty or staff member may always withdraw their own Reportable Outside Activity Form request in its entirety, if neither the Department Head nor the Unit Head has taken any action on that submission request. This is done by opening the form and selecting the red "Withdraw this disclosure" button. After an entry has been withdrawn, it will still remain visible on the submission screen. However, it will be permanently labeled as "Withdrawn."
If the Department Head and/or Unit Head is in the process of reviewing a Reportable Outside Activity Form, the form cannot be withdrawn. As a courtesy, contact your Department Head and/or Unit Head to inform them of the issue and note the date that you submitted the erroneous form so they can deny that form., If appropriate, submit a corrected entry for review.
Q14. How many forms should I submit?
A faculty or staff member can include all of their current activities on one (1) Reportable Outside Activity Form by selecting the "+ Add activity" button under the appropriate activity type. A separate ROA Form for each individual activity is discouraged.
Q15. What if I want to submit an additional activity, but I do not want to confuse the reviewer with duplicate items that have already been reviewed for the current fiscal year?
Once you select the "Submit a new form" button, you can add additional activities by selecting the "Add activity" button within any category. If you are concerned that duplicate items will be confusing to the reviewer, you should type, "already [approved/denied] on [insert date]" in the comments box next to each entry that has already been reviewed.
The form is sent to your Department Head for initial review once it is submitted. After the Department Head makes their recommendation, it goes to the Unit Head or the Unit Head’s designee(s). Unit Head is defined by Policy III.B.1 as your "applicable dean, vice chancellor, chancellor, associate or assistant vice president, vice president, executive vice president for business and finance and treasurer, associate or assistant provost, provost, or president who has executive management responsibilities for supervising the employee."
Q17. How can I determine the status of my submission?
If your submission has been approved or denied, you should receive an automatic email notification.
Alternatively, you can always log in to the online Reportable Outside Activity system and select the "My disclosures" tab. You will see the Activity Status appear in the box on the right hand side. It will let you know whether your submission is awaiting review by either your Department or Unit Head or whether it has been approved or denied.
If you need additional information on the status, you must contact either your Department Head or Unit Head directly.
Q18. How long before I will get a response?
In accordance with Policy III.B.1, your Unit Head should review within ten (10) days of receiving a properly completed ROA Form. If the Unit Head cannot determine whether the Reportable Outside Activity you submitted poses a conflict of commitment, they will forward it to the Outside Activities Officer to evaluate and make the determination in a timely manner.
Q19. I have submitted my ROA Form. Do I also need to complete a Conflict of Interest Disclosure Statement?
If the activities listed on your ROA Form include anything in which you have a financial interest, as defined by Policy III.B.2, you will need to complete a Conflict of Interest Disclosure Statement. For more specific guidance, see the Conflict of Financial Interest frequently asked questions.
Q20. What if I have additional ROA questions?
For more specific guidance, see the enhanced list of Reportable Outside Activity frequently asked questions.
Information for Department and Unit Heads Who Are Reviewing the Reportable Outside Activity (ROA) Form
Q21. How will I know I have something to review?
When an ROA Form is submitted by a faculty or staff member for review, the applicable Department Head, Unit Head, or official designee will receive an email notification that a new outside activity is in the queue, awaiting review. An email notification will occur every seven (7) days. Although an email notice will be sent only once a week, a reviewer may go into the system more frequently to ensure there is nothing outstanding to review.
Q22. What if I am not receiving my seven-day email notifications?
All reportable outside activity email is sent to your official Purdue email address. If you are not receiving email notifications, please update your contact information. You can update this by either logging in at http://www.itap.purdue.edu/directory or by contacting your business office to correct data received from Human Resources.
Q23. How do I log in and conduct a review?
- Go to the ROA Form at https://webapps.ecn.purdue.edu/VPEC/ROA
- Log in by typing your Purdue Career Account username and password. Please note: The system only acknowledges the username and password of a Department Head or Unit Head, or official designee. An assistant or business manager's username and password will be rejected by the system for purposes of rendering a review decision.
- After you have logged in, select the "Review disclosures" tab on the "My outside activity disclosures" page.
- The name of the individual who made the submission will appear highlighted in blue. Click on the name.
- Scroll to the pale blue box for an activity.
- Select your recommendation or decision and post any applicable comments.
- Repeat steps 5 and 6 for each activity on the form.
- After the review is complete, type your first name, middle initial and last name in the "Signed by" box. Please note: Inserting an electronic signature is prohibited by the system.
- Type your Purdue Career Account password.
- If you are a Department Head, select the blue "Sign and submit for review" button. This will forward the submission to the Unit Head for final review.
- If you are a Unit Head, selecting the "sign and submit" button will conclude the review.
Q24. Should I make a copy of the form for my records?
No. The online Reportable Outside Activity system will keep track of all submissions and corresponding approvals or denials that have been submitted. Department Heads and Unit Heads will always have access to this data. However, you will need to independently maintain any special statistics you have historically collected. For example, the system will not run special year-to-year statistics on the number of days reported by an employee in performing a specific activity.
Q25. What if I need more information?
Email the faculty or staff member directly with any additional clarification questions. Once a response is received, the review can be completed. The Department or Unit Head should post a summary of any faculty or staff member's response used to complete the review in the "Comments" box. A copy of the faculty or staff member’s written response should be retained for your office records.
Q26. What if a form was submitted in error?
A faculty or staff member may always withdraw their own Reportable Outside Activity Form request in its entirety, if neither the Department Head nor the Unit Head has taken any action on that request. However, if it appears that an entry is a duplicate that did not get withdrawn by the faculty or staff member, you should verify this with the employee and "deny" the request submitted in error. Please type, "This form was submitted in error and has been replaced by a subsequent submission" in the comment box as justification for the denial.
Q27. Can a faculty or staff member see any of the comments I posted during my review?
Yes. The faculty or staff member can see all comments posted.
Q28. What if I am leaving the University?
You should continue to review any incoming reportable outside activities until your last day of employment or until a new official Department Head or Interim Head has been appointed, whichever occurs first. Please note: The ROA system will not allow a new Department Head or Interim Head to be reassigned until the change has been made in SuccessFactors.
Q29. What if I have been incorrectly designated as a Department Head?
The system will not allow you to personally update any changes to personnel.
Please note: The Office of the Vice President for Ethics and Compliance is not responsible for updating changes to personnel. Our office relies on the information provided by the ROA system. The Reportable Outside Activity database is updated based on information provided by SuccessFactors. You or your successor must contact your business office to ensure a change to Department Head has been input into the system accordingly. Once your business office has made this request, it may take up to thirty (30) days for the change to be reflected in the ROA system.
Q30. How will a new Department Head access outstanding submissions sent to a former Department Head?
Once a change of Department Head has been updated in both SuccessFactors and the Reportable Outside Activity database, the new Department Head will begin to receive weekly notification reminders of any items awaiting review. The system will automatically reassign any old submissions still awaiting review to the new Department Head.
Q31. Is there a way to observe all the current disclosures submitted to my area?
Yes. You can review all of the disclosures for your area.
- Once you have logged in, select the "Review disclosures" tab.
- Select "All disclosures." (It will take a few seconds to generate the list.)
- The "Activity status" column on the right-hand side will advise you as to whether each specific entry on a form has been approved, denied or is awaiting review.
Q32. Is there a way to run a year-end spreadsheet of all outside activities submitted to my area?
Yes. You can run a year-end spreadsheet for your area.
- Once you have logged in, select the "Review disclosures" tab.
- Select "All disclosures."
- Select "Export to Excel" button.
- Select the "Open" button.
Q33. How long do I have to respond?
In accordance with Policy III.B.1, a review should be conducted by the Unit Head within ten (10) days of receiving a properly completed Reportable Outside Activity Form. If, after requesting additional information from an employee, you cannot determine whether the Reportable Outside Activity submitted poses a conflict of commitment, forward it to the Outside Activities Officer to evaluate and make the determination in a timely manner.
Q34. Additional Department and Unit Head Questions
For specific inquiries, contact the Office of the Vice President for Ethics and Compliance at vpec@purdue.edu or Deborah Trice at compliance@purdue.edu.