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Disclosure of Outside Professional Activities at Penn State

Revised November 01, 2023

Introduction  

A conflict of commitment can occur when your external obligations (either paid or unpaid) conflict with or appear to conflict with your institutional responsibilities. For example, participating in outside professional activities such as teaching at another institution, starting your own company, or engaging in outside consulting work can cause conflicts of time and effort. The University encourages you to participate in outside professional activities. To minimize or eliminate these conflicts and ensure that your outside activities don't compete with the University, Penn State has policy AC80. This policy outlines the requirements for pre-approval and disclosure of outside professional activities for faculty members. 

Who Does Policy AC80 Apply To? 

Policy AC80 applies to all full-time Penn State faculty on either a 36- or 48-week appointment, (but does not apply to adjunct or part-time faculty). This includes:  

  • Tenure track faculty  
  • Non-tenure track faculty, including but not limited to: 
  • Research faculty 
  • Teaching faculty 
  • Clinical faculty 
  • Professors of practice 
  • Penn State Health physicians with a College of Medicine appointment.  

 

The policy also applies during sabbaticals.   

What Activities Require Disclosure? 

All outside professional activities that fall in your area of expertise but are outside the scope of your University responsibilities require disclosure. This includes activities that fall outside of your appointment period, such as in the summer.   

Examples include: 

  • Teaching at another institution  
  • Serving as an expert witness 
  • Private consulting that does not involve research  

NOTE: The term research applies to work that is intended to result in either a publication and / or a public presentation. 

What Activities Require Prior Approval? 

There are specific activities listed in Policy AC80 that require prior approval before you can engage in them. These activities usually involve significant time commitments or are subject to U.S. federal government regulations related to international entities.  Remember that ALL activities require disclosure, even if the activity was previously approved. Activities that require prior approval will also require disclosure.  

Examples include: 

  • Outside teaching during your appointment period 
  • Filing paperwork to start your own company 
  • Involving students in your outside professional activity 
  • Private consulting that does involve research 

NOTE: The term research applies to work that is intended to result in either a publication and / or a public presentation. 

Difference Between Prior Approval and Disclosure 

It is important for you to know that prior approval and disclosure are two separate requirements under Policy AC80.   

Prior approval involves seeking approval for planned activities, while disclosure involves documenting activities you have already done. Since sometimes plans can change, you must submit a disclosure within 30 days of starting a new activity, even if the activity was previously approved.  

For example, if you plan on teaching at another institution during your appointment period, you must first secure prior approval. Then, submit a disclosure within 30 days of accepting the outside teaching role or starting the outside teaching, whichever is earlier.    

 What Activities are Excluded from Disclosure? 

Activities unrelated to your expertise, scholarly activities, and activities conducted as part of an approved sabbatical plan do not require disclosure. Scholarly activities, which are expected professional responsibilities, generally don't need prior approval or reporting. However, colleges or departments may impose limits on time spent on these activities. 

Although scholarly activities are excluded from time reporting under Policy AC80, you may need to disclose them in COINS under Policy RP06 if the compensation exceeds certain income thresholds determined by U.S. Federal funding sources. 

Time Limitations 

You may participate in outside professional activities for up to 40 hours a month. These hours are inclusive of weekdays, evenings, and weekends. Activities conducted outside your appointment period are not subject to time limits.  

Exceeding the time limit requires prior approval from your Department Head, Dean, and in some cases the Office of the Provost.  

When to Disclose 

All disclosures related to outside professional activities occur in COINS, the University’s Conflict of Interest System. Be sure to update your disclosure in COINS within 30 days of starting a new outside professional activity. Ongoing outside professional activities should be disclosed annually when notified via email, and your disclosure should be up to date before applying for sponsored funding.    

Consequences of Undisclosed Conflicts 

Undisclosed conflicts of commitment can have serious consequences, such as: 

  • Noncompliance: The U.S. Federal government has become increasingly concerned with undisclosed relationships and time commitments. Securing prior approval and disclosing all outside professional activities helps you to stay in compliance not only with University policy, but also with an increasingly complex landscape of U.S. federal regulations and guidelines. 
  • Impacts to Reputation: Conflicts of commitment can also harm your reputation and the reputation of the University if it appears that external activities take priority over your responsibilities to the University and its students. 
  • Impacts to Student Learning: Excessive outside professional activities can reduce your availability for teaching and research, negatively impacting overall student learning and development.  

It is in your best interests to request pre-approval for all applicable activities per policy AC80 and disclose all outside professional activities to ensure that any conflicts can be appropriately managed to minimize or reduce any associated risks.  

 

Questions?