Frequently Asked Questions About Time Commitments Reporting

1. Who should I contact if I have specific questions about time commitments to my outside activities?

Your Dean or Director’s Office is your primary contact point for questions on your time commitments to outside activities.

 

2. Who should I contact if I have specific questions about financial interests associated with my 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: coiprogram@research.wisc.edu.

 

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.

 

4. How do I know if an outside activity should be reported?
1. If you are engaging in an “ordinary institutional activity” as listed below and did not receive compensation, the activity is not reportable:
1. occasional lectures, colloquia, seminars, etc., given at colleges and universities and at meetings of professional societies;
2. evaluation of colleagues at other colleges and universities through participation in program evaluations and tenure and promotion reviews;
3. invited or juried installations, shows, or exhibitions;
4. musical, literary or theatrical performances;
5. preparation of monographs, chapters and editorial services for nonprofit educational organizations;
6. service on review panels for the federal government;
7. service on advisory committees and evaluation panels and nonprofit foundations and educational organizations;
8. extension work assigned by the University;
9. leadership positions in professional or scholarly societies;
10. other discipline-specific ordinary institutional activities may also be identified after review by your Dean or Director’s Office.
2. Payments from UW-Madison or from an appointment at UW Health or the VA that was arranged by UW-Madison, or a royalty payment from WARF do not need to be reported.
3. All compensation received, whether from ordinary institutional activities or outside professional activities, must be reported with the single exception of payment from the federal government for service on a grant panel.
4. If you will have a financial relationship with an entity and you will be part of a contract or other agreement that entity will have with UW-Madison, the relationship must be reported. If you will have a leadership position with that entity, such as being an executive or a trustee, the relationship must also be reported.
5. If you will receive any research support from any entity, foreign or domestic, it must be reported unless it has been approved by UW Research and Sponsored Programs.
6. Some other outside professional activities that must be reported include teaching, research or administration under contract to another organization, employment outside of the university in your field of academic expertise, forming, managing or operating a company, consulting, membership on a Board of Directors or Advisory Board, expert witness service, and presentation at a conference or symposium on behalf of a company.

 

5. Doesn't this new policy contradict the "Wisconsin Idea" – learning from our findings and then distributing to the rest of the state?

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.

6. Is the total amount of time per year or month?

The definition of the number of days permitted without prior approval is per month of the contract period.

7. Do I have to report a second job if it is not related to my university employment?

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.

8. If I work for 8 hours in a day, then am I free to do other outside activities that are related to my profession and not count it towards the 24-day limit?

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 will exceed the indicated time limit, regardless of when that time commitment occurs.

9. What does ‘normal work hours’ mean?

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.

 

10. If I go over the annual allowable time, do I need to get the Dean’s approval?

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.

11. I am doing service considered to be ordinary institutional activities nationally, so I don't have time for teaching or service to UW-Madison anymore.

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.

 

12. Do I need to report time spent reviewing federal grants for a study section?

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.

 

13. Which of the following should I report for time spent reviewing grants for a study section: a) time spent reading and reviewing each grant; b) travel time to attend the study section; c) time spent at study section?

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.

 

14. If I received compensation for reviewing grants, do I need to report: (a) time spent reading and reviewing each grant; (b) travel time to attend the review meeting; or (c) time spent at the review meeting?

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.

15. Is attending a scientific meeting that is not associated with a ‘professional society' (e.g., a Keystone meeting) considered an ‘ordinary institutional activity"?

 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.

16. Does 'editorial service' mean acting as an editor or as a reviewer of manuscripts?

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.

 

17. If I do editorial service for a journal that is not associated with a professional society, is this considered an ordinary institutional activity?

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.

 

18. How do I distinguish between volunteer activities and reportable activities?

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.

 

19. Is volunteering to teach soccer more than two days a month reportable?

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.

 

20. What about programs offered by official UW affiliate organizations such as WARF or UW Health? Are these considered university activities or outside activities?

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.

 

21. Regarding teaching, is it acceptable for one’s faculty colleagues to cover for another because the latter has an important "Ordinary Institutional Activity" like attending a study section or a key scientific meeting?

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.

22. What if I am invited to give a seminar overseas and my host pays my way? Is that allowed?

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.

23. I don’t always get a receipt if someone else is paying my way to an international or domestic conference. So how do I report this?

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.

 

24. Is international collaboration allowable?
    The UW-Madison encourages collaboration, domestic and international, when carried out within the guidance of existing policies. When one participates in international collaboration, time spent on travel, research support not managed by UW-Madison, and all financial compensation and honoraria received must be reported on the Outside Activities Report. Recipients of federal grants should also report these activities in their Biosketch, Other Support documents in new grant applications, and progress reports.
    
    
25. If a lab member asks an international colleague for expertise, is this a concern?

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.

26.  If I received $500 for a virtual seminar presented to a foreign university, is that a problem?

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.

 

27. Does this policy apply to postdocs and graduate students that have a PA, RA or TA position at the university?
    The COC policy currently does not apply to postdoctoral fellows and graduate students; however, Dean’s offices may make individual requests for outside activity reporting from these individuals.

 

28. Is a UW-Madison spinout (i.e., a company based around IP developed at UW-Madison from UW-Madison research) considered an organization that is “not directly university-related?

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 extension programs that occur both in the state of Wisconsin and outside the state as part their normal job responsibilities is 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.

 

31. If a faculty or staff member forms a company that provides fee-for-service activities, is that activity reportable?

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.

 

32. If a faculty or staff member plans to serve as an expert witness for litigation, is this reportable?

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.

Keywords: conflict of commitment, COC, time commitment, outside activities, outside professional activities, ordinary institutional activities