Pursuant to University, State, and Federal policies, Outside Activities Reporting (OAR) is required annually from all Faculty, Academic Staff/Limited Appointees with appointments at 50% or greater, Principle or Co-investigators on federal grants, and individuals with active management plans from the Conflict of Interest Committee. The OAR Form is generally completed during the annual reporting process, which must be submitted by April 30. Employees who are required to report will receive a link to submit their disclosure.
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Outside Activities Reporting Guidelines for Faculty, Academic Staff, and Limited Appointees
Who must report and when?
The University of Wisconsin System requires an annual report from all faculty, academic staff and limited appointees who engage in remunerative outside activities in their field of professional interest whose appointments are half-time or more for the period under contract to the UW System. Faculty and staff who do not complete the Outside Activities Report by April 30 each year will be considered “not in good standing” and ineligible for future salary adjustments, including pay plan adjustments, until they comply with Outside Activities Reporting requirements.
There are additional reporting requirements for employees involved in research or sponsored programs. See “Additional and Related Reporting Requirements” below.
The OAR form gathers activities for the prior year and current activities, and staff are required to report any changes in their outside activities immediately. To provide an update to an existing OAR Report or to submit at the request of the Office of Sponsored Programs, please complete the OAR Form at: https://uwm.edu/oarform. If an employee has a joint appointment, they must address activities as they relate to each appointment. The report also covers activities that occur during the full year, even if an employee was not under contract to the University for part of that time.
Definitions of OAR Form Terms:
A Remunerative Relationship is any relationship that results in payments, transfer of goods or provision of services to the reporting staff member.
An Organization is any corporation, partnership, proprietorship, firm, enterprise, franchise, association, trust or the legal entity other than an individual or body politic (see Wis. Admin. Code § UWS 8.02(12).
Professionally Related Activities are activities related to the staff members’ field of academic interest or specialization.
Ordinary Professional Activities are those activities which extend an unclassified staff member’s normal institutional responsibilities of teaching, research and service to serving other public institutions, organizations, and professional societies. Examples of such ordinary professional activities would be:
- Occasional lectures, colloquia, seminars, etc., given at colleges and universities and at meetings of professional societies.
- Preparation of monographs, chapters and editorial services for nonprofit educational organizations.
- Service on advisory committees and evaluation panels for government funding agencies, nonprofit foundations and educational organizations.
- Leadership positions in professional societies.
Which activities must you report under UWS 8.025?
Professionally related outside activities occurring during the time you are under contract to the university for which you received net remuneration, not including ordinary professional activities. In addition to monetary payments, remuneration includes goods, services, and other items of value if they are compensation for services you perform.
- The names of organizations or businesses for which net remunerative outside activities were performed, the type of activity (consulting, teaching, research, writing, etc.) and the aggregate time spent (days) in that activity. Royalties from writing and patents need be reported only in the year that they first appear.
- You must name the organization or source and indicate the aggregate amount of time in days spent in outside activities with that organization. You must also identify if you received $5,000.00 or more compensation per year from a single source. If you believe you should not publicly identify the name of the organization, you must receive approval from your dean to withhold the name (e.g., if revealing the name would be damaging to the organization’s legitimate competitive interests).
- Any remunerative relationships that you had with nongovernmental sponsors of university research, teaching or training for which you are principal investigator. If these relationships exist, you must report the name of the organization.
Officerships and Directorships
Officerships, directorships, trusteeships that you or members of your immediate family hold in businesses or commercial organizations related to your professional field.
Ownership interests in organizations related to the employee’s academic area of specialization, provided that you and/or your immediate family collectively own more than 10% of the equity.
This is separate from the requirement to report all remunerative relationships related to the employee’s academic specialization. Thus, if an employee has an ownership interest of less than 10% that is still remunerative, it must be reported as a remunerative relationship but not as an ownership interest.
Those activities which do not need to be reported include:
- Activities for which remuneration comes from university administered funds (e.g., teaching and innovation awards, etc.).
- Remunerative ordinary professional activities (see definitions above).
Managers and Supervisors (or other individual designated by the institution to review outside activity reports) are responsible for reviewing the information provided on outside activity reports submitted by employees and determining whether any reported activities may pose potential conflicts of interest. If the potential for conflict exists for faculty and staff who are not engaged in research, reviewers should meet with the employee to provide guidance on how to avoid conflicts of interest and, if necessary, create a written conflict management plan and upload the plan to the employee’s OAR forum. The reviewer may also determine that a conflict exists and cannot be avoided, in which case the employee should be advised to terminate the activity that causes the conflict.
If the potential for conflict exists for any faculty and staff engaged in research, the reviewer should notify the Research Conflict of Interest Committee by sending an email to firstname.lastname@example.org.
Reviewers should also assess:
- Whether the employee disclosed all reportable activities. If not, reviewers should discuss any missing activities with the employee and return the OAR to them for necessary additions.
- Whether the employee disclosed sufficient details about any relevant entity and its business purpose/mission. If not, reviewers should discuss any missing information with the employee and return the OAR to them to include additional detail. There are comment sections in the OAR, which can be utilized, and/or employees can upload attachments if more room is needed.
Additional and Related Reporting Requirements
Research Activities and Potential Conflicts
In addition to the requirements under UWS 8, all individuals who have research responsibilities should determine whether they are required to report any outside activities using the OAR for under UWM’s Research Conflict of Interest Policy and the Public Health Service (PHS) Financial Conflict of Interest Policy. OARs are reviewed by the Research Conflict of Interest Committee.
Under these policies, the following employees must report their outside activities using the OAR form:
- All UWM faculty, regardless of appointment level
- All PIs, co-Investigators, and senior/key personnel on current federal grants
- All individuals with an active management plan from the RCOI Committee
Staff who have paid or unpaid relationships with foreign entities, including a foreign talent recruitment program and which were not managed through UWM, must report such relationships using the OAR form.
If the relationship includes remuneration, reportable compensation could include cash, research funding, honorific titles, career advancement opportunities, promised future compensation or titles, or other types of remuneration or other consideration. This does not include an invitation by a foreign state to simply attend or present work at an international conference.
State of Wisconsin Statement of Economic Interest
The annual economic interests reporting requirement administered by the Office of the Board of Regents is separate from and in addition to the outside activities reporting requirement. Pursuant to Wis. Admin. Code § UWS 8.06, the president, vice presidents, chancellors, and all contracting personnel must file a statement of economic interests with the Office of the Board of Regents annually, by April 30.
Faculty Expert Witness Service
Per UWM Faculty Policies and Procedures sec. 5.37 and UWS 8.04, a faculty member who intends to serve as an expert witness in any civil or criminal case must promptly report the nature of the case to their dean before such service begins. The dean will determine whether such service constitutes a conflict of interest based on the nature of that service and the faculty member’s duties. If the faculty member undertakes such work, it must also be reported as an outside activity using the OAR.
Institutional Ethics Committee:
Wis. Admin. Code § UWS 8.035 requires that each institution shall have an institutional ethics committee, “whose function shall be to provide to any member of the unclassified staff consultation and advice on the application” of Chapter UWS 8 Unclassified Staff Code of Ethics. For academic staff, the ethics committee is the Academic Staff Committee. The Faculty Ethics Advisory Committee is the ethics committee for faculty.
- Code of Ethics SYS 1290
- UW System Administrative Policy Guidance for SYS 1290
- Office of Research Integrity, Public Health Service, Federal Reg 42cfr50
- National Science Foundation, Grant Policy Manual, Section 510
- Wisconsin Administrative Code, Section UWS 8.025
- UWM Academic Staff Personnel Policies and Procedures, Chapter 113
- UWM Faculty Document 2466
- Provost’s Spring 2023 Outside Activities Disclosure Notification