Guidance for Submission of Annual APM 025 Report

For: Compensated Outside Professional Activities

Requirement:

Faculty in the Health Sciences Compensation Plan (HSCP) are required to submit to his or her Department Chair a signed annual APM 025 report, which describes and attests to the time spent in all Category I & Category II Compensated Outside Professional Activities (OPA) during the previous fiscal year. Category III compensated OPA, uncompensated OPA, and non-professional outside activities are not required to be reported (see definitions below).

Background:

The University recognizes that there is great value in activities conducted outside the University which advance and communicate knowledge through interaction with industry, the community, and the public. University Policies APM 025 and APM 670 (HSCP) address compensated and uncompensated outside professional and non-professional activities; and the applicable time limitations and reporting requirements. Additionally, APM 670 governs the dollar thresholds, type and amount of outside income that is due the HSCP; and that which may be directly retained by the individual. The HSCP also requires that a faculty member must meet his or her primary Department’s ‘good standing criteria’ in order to engage in any outside professional activity.

General Description:

The annual APM 025 report should be submitted on the attached form (“Annual APM 025 Report of Compensated Outside Professional Activity”). The report for OPA activities occurring during the preceding fiscal year is due by August 1st of the current fiscal year. The following elements should be included:

1)  Indication of whether the activity was Category I or Category II

2)  Number of days spent on each activity

3)  Description of your role and the work performed

4)  Type of compensation received

5)  Name and description of the entity for whom the activity was provided

6)  Range of the compensation amount received

Definitions and Guidance:

  1. Compensated Outside Professional Activities

Compensated refers to income, fees, stipends, honoraria, royalties; and/or the receipt of assets or capital, realized or having the potential to become realized.

Outside Professional Activities (OPA) are those activities that are within a faculty member’s area of professional, academic expertise; and that advance or communicate that expertise through interaction with industry, the community, or the public.

2.  Uncompensated Outside Professional Activities

Uncompensated OPA do not need to be reported and are not subject to the annual time limitations. They, however, can potentially raise issues of Conflict of Commitment. Henceforth, the Department Chair may request, and the faculty member shall be obliged to provide, information concerning uncompensated time spent related to OPA. The information may be reported using the “Compensated Outside Professional Activities” form by identifying uncompensated time accordingly.

3.  Compensated or Uncompensated Outside Non-Professional Activities

Outside activities that are not directly related to a faculty member’s area of professional, academic expertise do not need to be reported, and are not subject to the annual time limitations. However, any activity that interferes with the successful performance of a faculty member’s University obligations represents a Conflict of Commitment and would be considered a violation of University policy.

4.  Time Limitations on Compensated Outside Professional Activities

Faculty members may engage in Category I and Category II compensated outside professional activities for up to 48 days annually for a full time fiscal-year appointment; or 39 days annually for an academic-year appointment. The number of days is pro-rated for part time faculty. The limit on the number of days devoted to compensated OPA applies regardless if they are conducted during the normal work week, on weekends, evenings, vacations, or paid leaves.

  1. Categories of Compensated Outside Professional Activities

Compensated OPA are divided into 3 categories in terms of the extent to which they may raise issues of Conflict of Commitment. For each category, there are different requirements as to prior approval, annual reporting, and inclusion in the time limitations.

1)  Category I

Category I activities require prior authorization by the Vice Chancellor for Health Sciences. These activities must be reported annually and are subject to the annual time limitations. Category I activities are likely to raise issues of Conflict of Commitment. They include but are not limited to:

A)  Assuming an executive or managerial position outside the University

B)  Submitting or administering, outside of the University, a grant or research study that would ordinarily be conducted under the auspices of the University

C)  Establishing an employment relationship as a salaried employee outside of the University

D)  Assuming a faculty position or engaging in teaching at another institution

E)  Engaging in professional/clinical practice outside the University

F)  Engaging in any other compensated OPA which common sense and good judgment would indicate are likely to raise issues of conflict of commitment

2)  Category II

Category II activities do not require prior approval, but must be reported annually and are subject to the annual time limitations. Category II activities are unlikely to raise issues of Conflict of Commitment. They include but are not limited to:

A)  Providing expert testimony in administrative, legislative, or judicial proceedings

B)  Providing consulting services

C)  Serving on the Board of Directors , or an Advisory Board of an outside entity

D)  Providing services for industry

E)  Engaging in other compensated OPA not mentioned in Category I or III, but which common sense and good judgment would indicate are unlikely to raise issues of Conflict of Commitment.

3)  Category III

Category III activities do not require prior approval, do not need to be reported, and are not subject to the annual time limitations. These activities do not ordinarily raise issues of Conflict of Commitment. Category III activities are accepted as integral to and part of a faculty member’s scholarly and creative work. They include but are not limited to:

A)  Serving on a Governmental committee, panel, or commission

B)  Acting in an editorial capacity for a professional journal

C)  Reviewing scholarly books or manuscripts

D)  Reviewing grant, research, or contract proposals

E)  Attending and presenting talks at scholarly colloquia and CME conferences

F)  Developing scholarly communications

G)  Serving as a committee member or an officer of a professional scholarly society

H)  Serving as an examiner for a national specialty board

NOTE: Activities outside the University which are provided as part of a University Contract, Affiliation Agreement, or Service Agreement are not considered Outside Professional Activities for purposes of APM 025 reporting.

  1. Number of Days (# Days)

The number of days represents time spent in each activity and should be reported in aggregate for the reporting period for each entity. The days should be approximated to the nearest one-half day increment. The University recognizes and supports the diverse hours and schedules of faculty members. Exercise sound judgment and reason when determining what constitutes a ‘day’ of Outside Professional Activity.

  1. Description of Role and Activity

Identify the nature of your role/relationship with the entity for which you performed the activity (e.g., Consultant, Board Member, Adviser, Officer, Employee); and briefly describe the work performed.

  1. Type of Compensation

Briefly describe the type of compensation you received from the entity for which you performed the activity; e.g., honoraria, income, stipend, fee, ownership or equity interest, stock or stock options, partnership interest, salary, royalties, or other (please explain).

  1. Name and Description of Entity

Provide the legal name of the entity for which the activity was performed, and briefly describe the nature of the entity’s business.

  1. Compensation

Select the corresponding dollar range of compensation you received for each listed activity. The Department Chair may request, and the faculty member shall be obliged to provide, more specific information regarding the dollar amount associated with each activity.

11.  Faculty Member’s Signature

The Faculty member’s signature attests to the understanding that outside professional income for Category I and II activities earned above the APM 670 thresholds (greater of $20,000 or 20% of X+X’+Y’’) must pass through the HSCP; and that the listed activities are a full and accurate disclosure of his or her Category I and II compensated OPA.

  1. Department Chair’s Signature

The Department Chair’s signature affirms that the ‘Annual APM 025 Report of Compensated Outside Professional Activities’ was received and reviewed for the following:

1)  The Information submitted for each listed activity is complete

2)  Category I activities (if any) were pre-approved

3)  Annual time limitations were not exceeded

NOTE: The Department Chair’s signature does not represent an independent verification as to the accuracy of the individual faculty member’s annual APM 025 report.

NOTE: The Department Chair is responsible to notify the Dean’s Office regarding non-compliance with APM 025 reporting; and of corrective actions which were implemented for a faculty member exceeding time limitations, or for engaging in unapproved Category I activities.

Guidelines for Submission of Annual APM025 ReportPage 1

Rev: 09/16/2011