Your Dean or Director’s Office is your primary contact point for questions on your time commitments to outside activities.
The COI Program Office should be your primary contact point for questions about financial interests associated with your outside activities. They can be reached via this email address: email@example.com.
3. What types of outside activities are there?
The UW-Madison recognizes two types of outside activities: 1) Outside professional activities, which are elective activities of an individual that may include contractual obligations, time commitments and personal financial interests; these must be reported in your Outside Activities Report; and 2) Ordinary Institutional Activities, which are typically scholarly or service activities undertaken on a voluntary basis as part of ongoing employment at the university; these typically do not need to be reported in your Outside Activities Report.
This policy does not prohibit participation in outside activities. It calls for prospective reporting of time committed to outside activities beyond the de minimus number of days indicated so that the university is aware of the time commitment and so that an evaluation of any potential impacts to the university can be made. During the review and approval process, alternatives may be offered as a way to manage time commitments to benefit of the employee and the institution.
The definition of the number of days permitted without prior approval is per month of the contract period.
If your employment outside of the university is not in your field of academic interests or specialization, you typically do not need to report it. However, if your employment is with a company that names you in contracts with the University, State of WI laws require that you report your employment in the Outside Activities Report (see FAQ 1d). If you are uncertain of whether your second job represents a material conflict or may have contractual obligations, consult your Dean’s or Director’s Office for additional guidance.
The conflict of commitment policy refers to any commitment of effort to any activity that needs to be reported and that, in aggregate with other reportable activities
Faculty and academic staff have an employment expectation that their institutional responsibilities will be fulfilled independent of an assignment of hours per day. Overtime is not permitted in contracts for employment of faculty and academic staff.
If an individual expects to exceed the annual allowable time commitments for outside activities, they must report the time commitments prospectively. The Dean or Director’s Office has responsibility and authority to review and approve or otherwise guide the time commitments of the faculty or academic staff member.
This level of national service should be included in annual progress reports so it can be reviewed by the Dean’s Office and properly acknowledged for its impact on the university mission. Teaching, as well as other faculty responsibilities, may be adjustable on a short-term basis with dean approval. However, longer-term commitments that prevent a faculty member from carrying out their normal teaching, research and service must be addressed through formal reassignment of duties.
Faithful completion of service obligations, such as in grant reviews for a U.S. federal agency, would be considered as an ordinary institutional activity and so time committed would not need to be reported absent other time commitments that might impact the ability of the individual to fulfill their university responsibilities.
Completion of service obligations, such as in grant reviews, would be considered an ordinary institutional activity and so time committed would not need to be reported absent other time commitments that might otherwise adversely impact the ability of the individual to fulfill their university responsibilities.
Time committed and compensation received for review of grants for US federal agencies does not need to be reported. However, the compensation received for review of grants for any non-federal entity, whether domestic or international, public, private or non-profit must be reported. Furthermore, the aggregate time committed to the latter activities may need to be reported in advance if they are expected to exceed the de minimus number of days indicated in the policy.
In nearly all circumstances this would be considered an ordinary institutional activity so long as there are no other factors that might otherwise adversely impact an assessment of time commitments to university responsibilities.
In nearly all circumstances, both of these would be considered ordinary institutional activities so long as there are no other factors that might otherwise adversely impact the ability of the individual to fulfill their university responsibilities. If the work being done includes financial compensation, then the work must be reported in the Outside Activities Report.
In nearly all circumstances this would be considered an ordinary institutional activity so long as there are no other factors that might otherwise adversely impact the ability of the individual to fulfill their university responsibilities. If the work being done includes financial compensation, then the work must be reported in the Outside Activities Report.
Volunteer activities are those where the individual freely gives time and effort, possibly including service that is related to their institutional responsibilities. If there are no contractual arrangements for dates of service, duration of time, compensation, or research support provided, then the voluntary activity does not have to be reported. Activities that include any types of contractual obligations or any type of appointment at another entity (honorary title, guest lecturer, adjunct professor, research scholar, etc.) must be reported.
This example of a volunteer activity, which is apparently not related to an individual’s professional experience and institutional expectations in research, teaching or service, would not be reportable under the conflict of commitment policy so long as there are no other factors that might otherwise adversely impact the ability of the individual to fulfill their university responsibilities.
Time committed to UW-Madison affiliates only needs to be reported if the work done for the affiliate is not part of your UW-Madison employment. For example, if your clinical position at UW Health is part of your faculty position at the School of Public Health and Medicine, it does not need to be reported; however, a clinical position arranged by you without involvement of your home department would need to be reported. Similarly, work with WARF programs that are arranged in collaboration with UW-Madison would not need to be reported.
Faculty seeking to exchange assigned teaching responsibilities, or any other institutional responsibilities, should follow their school/college and/or departmental procedures regarding reporting of colleague coverage of instruction before the proposed exchange. Faculty may not enlist postdoctoral fellows or graduate students to perform their assigned teaching responsibilities to engage in either outside professional activities or ordinary institutional activities, unless the postdoctoral fellow or graduate student holds an instructional appointment, and the assignment has been approved through the appropriate process in your school or college.
The University encourages this type of scholarly activity. University policies allow faculty and staff to make presentations regardless of whether the sponsor provides financial support. If it is received, financial compensation from either domestic or international entities at any level, including universities, is reportable according to UW System and federal regulations. Whether this activity constitutes a conflict of time committed or a financial conflict of interest needs to be evaluated in the context of the individual’s involvement in teaching, federally funded research, human subjects research, and other university responsibilities.
Researchers on federally funded grants are required to report the sponsor of the travel, the location, and the number of days required for the sponsored travel event, which are all reasonably known to the individual. A financial receipt is not requested for outside activities reporting. Requesting a reimbursement for travel expenses from UW-Madison does require a receipt, however.
Scholarly exchange with others, whether domestic or international, is encouraged by UW-Madison and is also considered to be an ordinary institutional activity. All unclassified staff are reminded of UW System requirements to identify and report all inventive acts achieved while employed by UW-Madison, and to also be aware of requirements of the Bayh-Dole Act regarding disclosure of inventions supported by grants from the US government.
Any compensation received from outside activities is reportable as required by UW System policies. For individuals participating in federally funded research or human subjects research, compensation in excess of $5000 is identified by federal definitions to be a significant financial interest and may be subject to additional review and institutional management.
Work performed for a UW-Madison spinout should be reported on your OAR if you receive any compensation, hold equity in the entity, or hold any fiduciary role within the entity in accordance with the COI Policy. You must also make a COC request as specified by the policy if time committed to the outside professional activity will go over the de minimus number of days allowed in the policy.
29. If a faculty or staff person is working on commercializing an idea, and a company hasn’t been formed, do they need to disclose the time they spend on it and if so, what amount of effort triggers that requirement? Does it matter if what they are trying to commercialize is related to their work at UW-Madison or not?
Outside activities are reported on an entity basis. If there is no entity, there is nothing to report. However, when an entity has been formed (e.g., a company or non-profit organization), that relationship needs to be reported. All unclassified staff are reminded of UW System requirements to identify and report all inventive acts achieved while employed by UW-Madison. They must also be aware of requirements of the Bayh-Dole Act regarding disclosure of inventions supported by grants from the US government.
30. If a faculty or staff person speaks at programs that occur both in the state of Wisconsin and outside the state as part their normal job responsibilitiesis this type of activity reportable as an outside activity (since it is part of their normal job responsibility)?
Normal job responsibilities (ordinary institutional activities) are not reportable unless the conditions in FAQ 1(c), (d), (e), or (f) are met.
If it is a personal business, both time and compensation are reportable, unless it is somehow unrelated to the person’s institutional responsibilities. If UW-Madison facilities are used as part of the business, then additional agreements between the company and UW-Madison are needed to assure that State Laws are not being broken. For the most part, use of UW-Madison facilities is not permitted without institutional agreement that includes full F&A for use of facilities.
Serving as an expert witness requires prior notification and approval of your Dean or Director. This is a long-standing rule from Chapter UWS 8 Unclassified Staff Code of Ethics.
33. Being on the board of or volunteer position at an agency /organization or a non-profit that is not our professional organization, yet could be associated with community organizing; advocacy for immigrants; housing rights; abolitionist organizations; ACLU; SPLC; Black Lives Matter; Climate Justice; Shelters etc. Because it is not our professional organization board, it appears that they are now requiring this to be reported?
Outside leadership activities such as service on a board related to work responsibilities need to be reported. Volunteer activities not related to work responsibilities do not need to be reported.
34. STS who have at least a 50% appointment and have a social work-related job outside of the university—all will have to report this work and have it approved prior to hiring them?
For an individual with a 50% or greater appointment, outside employment related to the UW work responsibilities needs to be reported but not approved prior to hiring.
35. How does this affect being a member of a labor union, especially those people in a voluntary leadership position? It is work-related since the whole purpose of the union is to look at labor practices at our job site (UW). Is this new policy stating if we attend meetings and provide leadership more than 16 hours per month on average, that we need to get this approved by our Dean??
Leadership positions in an outside organization must be reported regardless of time commitment. If the time commitment is greater than 2 days per month then prior approval of the Dean’s Office is needed.
36. What if we volunteer for a political campaign or a partisan advocacy organization—this must be reported? Or only reported if the campaign deals with issues related to our expertise? Or?
Most political campaigns and advocacy work are not reportable because they are not sufficiently related to UW–Madison responsibilities. However, if the outside partisan organization relates to people’s area of expertise and fiduciary duties are involved, the activity should be reported. If the time commitment is greater than 2 days per month then prior approval of the Dean’s Office is needed.
37. Am I right that all activity covered by this policy requires PRE-approval by our dean or director? This means that any impromptu outside volunteer activities are not allowed?
If the ‘impromptu’ activity requires more than 2 days a month, and it is related to the individual’s institutional responsibilities, it should be reported and pre-approved by the Dean’s Office.
38. Student employees are exempt, correct? I couldn’t find where this was stated.
The COC policy does not apply to undergraduates. See #27 for graduate students.
39. What policy or statute states that we must report the number of hours we work in outside activities? I’m not finding it in the rights and responsibilities of faculty policies, for instance.
UWS Chapter 8 is the foundational policy covering outside activities, particularly Section 8.04 which requires individuals to notify their Dean, Director, or other appropriate administrator by submitting a written statement describing the nature of any possible material conflict. The COC policy clarifies that spending more than 2 days per month on average towards outside activities presents the potential for material conflict.
40. It was stated that this is a common policy amongst our peer institutions. Which specific peer institutions require that they academic staff and faculty report their unpaid/volunteer activities?
UW-Madison does not require reporting of volunteer activities if they aren’t related to work responsibilities. COC policies that require reporting of time committed to outside activities are common among peers and many require prior approval of all time committed to outside activities. Revisions to COC policies are being carried out due to changes in requirements provided to institutions receiving federal grant funding.
41. Did this policy come up for discussion at the Faculty Senate? Any other faculty or academic staff governance bodies?
The COC policy was presented for consideration by the University Committee and the Academic Staff Committee. Comments received were incorporated into the policy.