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 PERA Conflict of Interest/Conflict of Commitment (COI/COC) module and
2) The Unit Head or OA Officer has given written approval for the the Exempt Employee’s participation in the Reportable Outside Activity described in the form.
The following instructions are provided to assist faculty and staff members in determining whether they have a Reportable Outside Activity and in completing the request in PERA. In addition, the guidelines provide department and unit heads with detailed instructions on how to complete a review.
Instructions for Faculty and Staff Members to Submit ROA Pre-Approval Request
Q1. Who gets my ROA Pre-Approval Request?
Q2. How can I determine the status of my submission?
Q3. How long before I will get a response?
Q4. I have submitted my ROA Form. Do I also need to complete a Conflict of Interest Disclosure Statement?
Q5. What if I have additional ROA questions?
Information for Department and Unit Heads Who Are Reviewing the Reportable Outside Activity (ROA) Form
Q6. How will I know I have something to review?
Q7. How do I log in and conduct a review?
Q8. Should I make a copy of the form for my records?
Q9. What if I need more information?
Q10. What if a form was submitted in error?
Q11. Can a faculty or staff member see any of the comments I posted during my review?
Q12. What if I am leaving the University?
Q13. What if I have been incorrectly designated as a Department Head?
Q14. How will a new Department Head access outstanding submissions sent to a former Department Head?
Q15. Additional Department and Unit Head Questions
Instructions for Faculty and Staff Members Who are Submitting Reportable Outside Activity (ROA) Pre-Approval Request
Q1. Who receives my ROA Pre-Approval Request?
That depends on several factors.
If you write-in an entity, it will be be routed to SPS Operations for screening and processing. It will then be routed as described below.
In most situations, the ROA Pre-Approval Request is sent to your Department Head for initial review. In some smaller departments, the request is routed directly to the Unit Head for a decision. If a Department Head has made a recommendation, the request will then be routed 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.”
If your request involves an activity or travel to a Foreign Adversary Nation, your request will be routed to Research Security and Export Control [“RSEC”] for review and recommendation. If RSEC does not recommend approval of the request, it will be routed to the Outside Activity Officer for review and recommendation or review and decision. If the Outside Activity Officer recommends approval of your request, it will route to your Department Head, if any, and the Unit Head/Unit Head’s designee.
The Unit Head may elect to refer the request to the Outside Activity Officer for review and recommendation or review and decision.
Reviewers may seek an ancillary review to request the review of another individual or office.
If your request names an entity that is subject to Export Controls and OFAC Regulations, it will be routed to RSEC for review. If the entity is a “restricted party” that is subject to Export Controls and OFAC Regulations and/or is on an entity list, your request will be denied.
If your pre-approval request has been approved or declined, you will receive an automatic email notification from NoReply-PERACOC@purdue.edu. If a Reviewer wants more information from you, you will receive a notice that Clarifications have been requested.
You may access your Disclosure Profile in the PERA COI/COC module and click on the “Pre-Approval Requests” tab. Click on the name of the pre-approval request. In the upper left corner of the screen, the status will be displayed as APPROVED, CLARIFICATIONS PENDING, DISCARDED, DECLINED, or PRE-SUBMISSION. The Assigned Reviewer will be listed for most requests.
Everyone involved in the review process is to act in a prompt and timely manner in making recommendations and decisions concerning your ROA Pre-Approval Request. If your activity involves a Foreign Adversary Nation and/or Foreign Adversary Entity including travel to a Foreign Adversary Nation, be aware that your request will undergo review by staff of Research Security and Export Control. This additional review has the potential to add two or more months to the review process. Keep 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 participate in the activity or travel until you receive approval from all reviewers. 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.
Q4. I have submitted my ROA Pre-Approval Request. Do I also need to complete a Conflict of Interest Disclosure Statement?
If the activities listed on your Pre-Approval Request ROA include anything in which you have a financial interest, as defined by the Individual Financial Conflict of Interest (III.B.2), you may need to complete a Conflict of Interest Disclosure Statement. For more specific guidance, see the Conflict of Financial Interest frequently asked questions.
For more specific guidance, see the enhanced list of Reportable Outside Activity frequently asked questions. You may also send your question to compliance@purdue.edu
When an ROA Pre-Approval Request is submitted by an Exempt Employee for your review, PERA will send an email notification that a new outside activity request has been submitted. The email notification will have a clickable link that will take you directly to the pre-approval request. You will not receive any reminders. It is important that you make a decision in a timely manner. Some reviewers find it helpful to create a rule that directs all emails from PERA COI/COC to a specific folder.
No. The PERA COI/COC Module will keep track of all ROA Pre-Approval Requests and related information. Department Heads and Unit Heads will have access to this data for those in their line of report.
Send a Request for Clarification within the COI/COC Module. Note that the discloser will receive one notification of the Request. Reminders are not generated by the Module. Please periodically review the pending requests in My Inbox.
Q10. What if a request was submitted in error?
The discloser can email compliance@purdue.edu or perahelp@purdue.edu to request that the request be discarded. Please include the basis for the request to discard.
Q11. Can a faculty or staff member see any of the comments I posted during my review? Currently, comments added within the Submit My Review section are not visible to the discloser. In order for the discloser to the see the comments, click on Comment on the left menu and copy your comments.
Q12. What if I am leaving the University or stepping down and Department Head or Unit Head?
Please notify perahelp@purdue.edu and provide notice of the last day in your role. If you know the name of the interim or person who will succeed you, please provide that information. You should continue to review any incoming ROA Pre-Approval Requests until your last day in your role, or until a new Department Head or Unit Head (or Interim) begins work.
Q13. What if I have been incorrectly designated as a Department Head or Unit Head?
Please notify perahelp@purdue.edu.
Q14. How will a new Department Head or Unit Head access outstanding requests sent to a former decision maker?
Once the change is recorded by SPS Operations, PERA COI/COC will send a notification of the pending requests.
For specific inquiries, contact the Outside Activity Officer at compliance@purdue.edu.