Disclosure of Outside Professional Activities
Georgetown University permits full-time faculty to engage in extramural activity outside the University, including remunerative activities. The Outside Professional Activities Policy (Faculty Handbook, Section III.C.9) notes that full-time faculty owe their primary professional allegiance to the University and their primary professional commitment to fulfilling the responsibilities of their University position. “Outside Professional Activities” are defined as those that “either (i) do not contribute to fulfilling a faculty member’s research, teaching, and service responsibilities to the University, or (ii) are conducted as a PI, co-PI, or in any other role listed as committing effort to a sponsored research, service or education grant or contract awarded through another institution or entity without a subcontract to Georgetown.”
Full-time faculty may engage in Outside Professional Activities that do not exceed an average of eight hours a week during the relevant academic year and which does not prevent the faculty member from fulfilling University obligations for teaching, research and service, including mentoring, committee and other assignments. Faculty are expected to avoid conflicts of interest and comply with the University’s Financial Conflict of Interest Policy, limit identification with the University to their formal titles and not give the impression that they are acting or speaking on behalf of the University unless specifically approved to do so.
Faculty must disclose all Outside Professional Activities. However the following Outside Professional Activities require approval by the Provost or campus EVP, who may, in conjunction with the relevant campus Conflict of Interest Officer, require a management plan to address any conflict of interest or conflict of commitment:
- Engaging in teaching by any mode of delivery as an Outside Professional Activity during the relevant academic year;
- Accepting a position in another academic or research institution;
- Serving as a PI, co-PI, or in any other role listed as committing effort to a sponsored research, service or education grant or contract awarded through another institution or entity without a subcontract through Georgetown;
- Accepting significant managerial or executive responsibilities, or titles that suggest such responsibilities, as part of any Outside Professional Activity; or
- Devoting more than an average of eight hours per week during the relevant academic year to Outside Professional activities.
Faculty may complete their annual Outside Professional Activities disclosure or report periodic updates as needed in GU-PASS.
Policy (Faculty Handbook, III.C.9. Outside Professional Activities)
A1: This policy applies to all full-time tenure line (FTL) and non-tenure line (NTL) faculty. Full time is defined as 75% FTE or above.
A2: You must disclose all Outside Professional Activitiesthat either (i) do not contribute to fulfilling a faculty member’s research, teaching, and service responsibilities to the University, or (ii) are conducted as PI, Co-PI, or in any other role listed as committing effort to a sponsored research, service or education grant or contract awarded through another institution or entity without a subcontract to Georgetown.”
A3: The activities that require approval through the Other Professional Activities Policy are as follows:
- Engaging in teaching by any mode of delivery as an Outside Professional Activity during the Academic Year;
- Accepting a position in another academic or research institution;
- Serving as a PI, Co-PI, or in any other role where you must commit and certify effort to a sponsored research, service or education grant or contract awarded to another institution or entity without a subcontract to Georgetown;
- Accepting significant managerial or executive responsibilities, or titles that suggest such responsibilities, as part of an Outside Professional Activity
- Devoting more than an average of eight (8) hours per week during the Academic Year to Outside Professional Activities.
A4: This process is being implemented as a result of revisions to the Faculty Handbook and the availability of a new review and disclosure module in GU-PASS.
A5: Yes, you must disclose it even if you have not received payment.
A6: Yes, you must disclose when you are conducting an Outside Professional Activity for a non-profit organization. Serving in a research role for a non-profit or other outside organization for which you must devote a certain percentage of effort and certify the effort requires the approval except if the work is done through a subcontract or subaward to Georgetown.
Q7: Must I disclose if I have my own business through which I engage in Outside Professional Activities?
A7: Yes, if you are the owner of a business, e.g., sole proprietorship, partnership, corporation or limited liability company, you are considered to be in an executive position that requires disclosure. Note that if you consult through your company for organizations that also fund your research at Georgetown, we ask that you list the organizations so that we can do a proper conflict review.
Q8: What types of roles at outside companies could appear to have executive or managerial responsibilities?
A8: Examples of roles include but are not limited to chief executive officer, chief operating officer, director, founder, partner, president, or principal or other such titles that carry fiduciary responsibility.
A9: You must only report if you take a teaching position during the academic year at another university or if you teach at another university during the month of August.
Q10: Do I need to report information on work that I perform on behalf of the University for outside entities?
A10: No, you do not need to disclose any activities that you are performing as part of your University activities. For example, if you are serving on an IPA at an outside agency and have an appointment for the purposes of the IPA, the appointment does not need to be reported.
Q11: Do I need to request approval for occasional participation in traditional scholarly activities such as (but not limited to) service on study sections and review panels, delivery of academic seminars, review, presentation or writing of scholarly papers, and service on editorial boards, so long as they do not conflict with assigned faculty duties.
A11: You do not need to disclose these activities if they are performed for a U.S. organization but you must disclose them if they are being performed on behalf of a foreign organization.
A12: Conflict management plans are tailored to the specific facts of each disclosure, however, the plans generally include the following provisions:
- A description of the financial interest or activity that has been disclosed;
- Acknowledgement that the faculty member is a University employee and owes his or her primary allegiance to Georgetown;
- Requirement to not share Georgetown’s confidential or proprietary information without an agreement between Georgetown and the organization;
- Disclosure of the outside activity in certain contexts;
- Oversight of University activities that could appear to be biased as the result of a faculty member’s participation in the outside activity.
A13: A conflict of interest may result when a faculty member’s outside activities or financial interests could appear to bias that person’s judgment in carrying out his or her professional University responsibilities. A conflict of commitment could arise when an outside professional activity or commitment could interfere with a faculty member’s ability to fulfill their obligations to Georgetown.
A14: The Faculty Handbook specifies that faculty are permitted 8 hours per week on Outside Professional Activities. There is no reference to the eight (8) hours being performed Monday-Friday. Therefore, there is no carve out for activities performed on evenings or weekends so if the activity meets the definition of Outside Professional Activity as specified in the Faculty Handbook, Section III(C)(9)(a).
Q15: Must I provide copies of the signed agreement associated with the Outside Professional Activity?
A15: Yes, please provide a copy of the signed agreement.
Presentation of Disclosure of Outside Professional Activities : Main Campus and Medical Campus
Questions may be directed to the following individuals in the Office of Research Oversight: