A message from Provost Glover: Requirement to disclose outside activities and financial interests

This memo is intended to clarify the responsibility of UF employees to disclose outside activities and financial interests. It is fair to say that, currently, there is some lack of understanding about the requirements and some inconsistency among units in reviewing and approving the disclosures, and we must all work to correct this situation.

While this has always been an employment requirement at UF, we need to ensure that UF Regulation 1.011 (see http://regulations.ufl.edu/regulations/uf-1-general/) on this subject is scrupulously followed, due, in part, to the heightened sense of urgency expressed in recent months by federal granting agencies and the federal government. For example, in Fall 2018, the Director of the National Institutes of Health (NIH), Francis Collins, issued a reminder to the research community to “disclose all forms of other support and financial interests, including support coming from foreign governments or other foreign entities…in accordance with the NIH Grants Policy Statement, [on] all applications and progress reports.”

UF also has an overarching interest in assessing the outside activities and financial interests of its employees. Faculty and staff members may participate in outside activities and hold financial interests as long as the activities and interests do not violate any state or federal law or regulations and provided the activities and interests do not conflict with their duties and responsibilities to the University. Determining violations and conflicts is often quite technical, and employees are not expected to have a complete grasp of this. That is why it is of paramount importance that employees disclose all outside activities and financial interests promptly so potential violations of law and potential conflicts can be assessed and resolved.

The Disclosure of Outside Activities and Financial Interests form can be found at http://aa.ufl.edu/resources/online-forms/. This form must be filed before an employee engages in an outside activity or acquires a new financial interest that may conflict with the university’s interests or become a cause for concern. Again, determining whether there is cause for concern may be a highly technical exercise. But the beauty of this system is that all the employee has to do is to report these activities promptly. It then becomes the responsibility of chairs and deans to review the report, assess whether there is a conflict or cause for concern, and initiate a discussion with the employee if necessary.

We know there is some confusion about what to report. UF Regulation 1.011 and the Disclosure form contain a detailed list and discussion about what to report, and this list is reproduced at the end of this memo. Despite the exhaustive nature of these two documents (or maybe because of it!) there are some recurring questions about what to report, and so we address these now.

1. Do I have to report outside activities for which I am not paid? The answer, in general, is yes. UF needs to have the opportunity to assess whether the time and effort you are devoting to other activities will interfere with your duties and obligations to UF.
2. Do I have to report compensation I receive on my professional travel? Yes, and this is true even if the travel was approved by the University. Compensation may include travel expenses and honoraria. You should certainly report any paid teaching activities at another institution.
3. Do I have to report scholarly work done under the auspices of another institution?  Yes. This applies to research activities conducted in the laboratories of other institutions.
4. What if my activities occur during the summer, outside of my 9-month academic appointment? You still need to disclose outside activities and financial interests to determine if there is conflict with your continued employment responsibilities and obligations at UF.

Please take the time to review the detailed list of reporting obligations below. After reviewing, if some doubt remains in your mind, your default action should be to disclose to the university for review and to discuss with your unit supervisor.

Reporting Requirements

The following activities and financial interests must be reported and approved prior to engaging in the activity:

1. Outside activities in which there is more than an incidental use of university facilities, equipment, and/or services. The completed Disclosure of Outside Activities and Financial Interests form is required to be attached to the Request to use these facilities, equipment or services.
2. Outside activities in which a university student or university employee is directly or indirectly supervised by the employee if the employee in any way supervises or evaluates the student or the employee at the University.
3. Management, employment, consulting, and contractual activities with, or ownership interests in, a business entity which does business or is proposing to do business with the University. In the cases of material financial and of managerial interests, the information required extends to the spouse and children of the employee, and for managerial interests, to relatives.
4. Management, employment, consulting, and other contractual activities with, or ownership interest in, a business entity which competes with the University.
5. Candidacy, election or appointment to a public office.
6. Required use of books, supplies, equipment, or other instructional resources at the University when they are created or published by the employee or by an entity in which the employee has a financial interest.
7. Professional compensated activities, including but not limited to, activities for which travel expenses, travel support, and honoraria are paid, teaching at another institution, or employment as an expert witness.
8. Business activities, including service on the board of directors or other management interests or position, with regard to a business entity in the same discipline or field in which the faculty or staff member is employed.
9. Any employment, contractual relationship, or financial interests of the employee which may create a continuing or recurring conflict between the employee’s interests and the performance of the employee’s public responsibilities and obligations, including time commitments. This includes any outside activity in which the employee is required to waive rights to intellectual property.
10. Outside activities and financial interests required to be reported under certain federal contract and grant regulations. Such disclosures may also need to be made at the time of the submission of the proposal.
11. Outside activities (employment, consulting, management and other contractual activities) and financial interests in an entity that supports the employee’s research or training activities in any way.
12. Outside activities (employment, consulting, management and other contractual activities) and financial interests in an entity that licenses technology invented by the employee.
13. Any other employment outside the University.
14. Any other outside activity or financial interest required to be disclosed under University Regulation 1.011.