Faculty Handbook Appendix G – Guidance for UAB Internal Activities, External Activities, and Professional Public Service Activities

Faculty Handbook Appendix G – Guidance for UAB Internal Activities, External Activities, and Professional Public Service Activities

Abstract:
This Appendix is designed to provide illustrative guidance to determine appropriate activity approvals and related leave requests.
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Appendix G

Guidance for UAB Internal Activities, External Activities, and Professional Public Service Activities

This Appendix is designed to provide illustrative guidance to determine appropriate activity approvals and related leave requests. The UAB Faculty Handbook and Policies and any other relevant official UAB policies supersede this Appendix in all cases. 1

Activity Types:

In managing conflicts of interest (COI) and conflicts of commitment (COC), determination of the correct activity type in the following Table 1 is essential to know if disclosure is required.

Table 1. Type of Employee Activity

Internal to UAB External to UAB
An institutional responsibility Internal Activity (IA)
Professional Public Service Activity (PPSA)
UAB-Related Activity Performed Outside of UAB
Performed for a non-UAB entity n/a External Activity (EA)

Institutional responsibilities are activities, duties, and responsibilities performed by an employee in the course of UAB employment and may include, but are not limited to, scholarship, research, research consultation, teaching, professional practice, administration, contracting or procurement responsibilities, or professional public service activities.

Internal Activities (IA) are activities sponsored by UAB above and beyond normal institutional responsibilities with additional compensation for a limited period of time (e.g., providing UAB continuing education) and performed within UAB Enterprise, 2 Birmingham VA Medical Center, or Children’s of Alabama.

External Activities (EA) are activities that draw upon the knowledge, skill, or abilities an employee uses to fulfill his or her institutional responsibilities at the UAB Enterprise but are performed for an entity outside the UAB Enterprise, whether or not for compensation. The use of UAB funds and resources is restricted.  3 Activity performed outside of UAB is typically an EA unless the activity meets criteria for a professional public service activity (PPSA).

Professional Public Service Activities (PPSA) are activities that are performed outside the UAB Enterprise and are considered part of an employee’s institutional responsibilities, whether or not separately compensated. Only specific activities provided to specific groups (Table 2) qualify as a PPSA. Domestic and international travel may be paid by UAB with approval, if not otherwise paid for or reimbursed by an outside organization.

UAB-Related Activities Performed Outside of UAB are activities for purposes of conducting UAB business, fulfilling institutional responsibilities, or participating in UAB Education Abroad. This is uncommon for most faculty. No compensation is associated with the activity, but domestic and international travel are typically paid by UAB with approval.

Activities outside of UAB:

Specific examples are provided in Table 2 to determine if an activity qualifies as a PPSA. Most activities performed outside of UAB are classified as External Activities.

Table 2. Differentiation of Professional Public Service Activities from External Activities

If the activity is: It is a PPSA if provided to: It is an EA if:
  • Professional studies (includes attendance of scientific/professional meetings)
  • Facilitating seminar, lecturing, presenting, performing, or speaking
  • Service/participation on advisory committees and/or scientific advisory boards
  • Service/participation on review panels including manuscript review, 4 grant/contract review, and/or academic program review
  • • Service/participation on boards of directors, as an officer, or any other role with fiduciary responsibilities 5
  • U.S. federal, state, or local government agencies
  • Institutions of higher education, academic teaching hospitals, medical centers or research institutes that are affiliated with an institution of higher education 6
  • UAB Enterprise affiliated entities
  • Nonprofit/ philanthropic entities
  • Professional societies, or professional associations, that are not affiliates of or affiliated with industry or other for profit entities
  • Civic groups
Provided to anyone else
External employment including moonlighting and/or locum tenens n/a All
Consulting for any type of organization n/a All
Establishing and/or supporting a start-up company n/a All
Serving as an expert witness n/a All
Academic appointment, title, or other affiliation with another institution of higher education, domestic or foreign n/a All

Disclosure and Leave:

Activity approvals and leave requests are separate processes, and both must be approved in advance through the appropriate supervisory path. IAs and EAs must always be disclosed, but only certain PPSAs require disclosure as shown in Table 3 below. If multiple activities exist within a single travel event (e.g., combination of PPSAs, EAs, and/or personal vacation in a single domestic or foreign travel event), then each activity must be disclosed with an appropriate leave request comprising the entire duration of the travel. Table 3 provides the appropriate disclosure and request for leave by type of activity being performed.

Table 3. Disclosures and Leave Requests by Activity Type

Activity Type COI Disclosure (UAB Forms): Leave Request (eLAS):
Internal Activity Request for UAB Internal Activity Approval None, unless required by unit or department 7
UAB-related Activity Performed Outside UAB Domestic: No disclosure required

International: UAB-Related International Travel Registration
Time Off Request – Leave type: Professional Leave
External Activity Request for External Activity Approval Time Off Request – Leave type: External Activity 8
PPSAy Domestic: No disclosure required unless investigator with reporting requirements. 9

International: if travel, UAB-Related International Travel Registration.
Time Off Request – Leave type: Professional Leave

Activity types and leave request are summarized in the flow chart below (Figure 1). If in doubt, disclose an activity performed outside of UAB with a Request for External Activity Approval.

Activity Expectations:

Faculty are expected to use best judgment in applying these guidelines as each activity is unique and details regarding funding and/or UAB’s relationship to an external entity may affect classification and reporting requirements. Regardless if the activity requires disclosure, faculty should be aware of potential COIs or COCs which may arise within an internal, external, or professional public service activity. Faculty responsibilities to identify, report, and (if appropriate) manage real or perceived conflicts are described in Section 5 of the UAB Enterprise Code of Conduct Policy. The following provides a few examples to demonstrate where further management is desired to safely mitigate risk to both the faculty member and the institution:

  • Professional public service on a Board of Directors for an institution of higher learning or a medical center may lead to a conflict of interest with UAB; or
  • Activities associated with a foreign entity, including domestic activities paid for entirely, or in part, by a foreign entity have potential for real or perceived conflicts through foreign influences.

If a potential conflict is determined, then the faculty member should work through the supervisory structure to determine the best course for conflict management. For conflicts associated with research, the UAB Conflicts of Interest Review Board may offer guidance and/or management plans to mitigate the conflict. Additional guidance may be obtained by contacting the UAB Office of Compliance & Risk Assurance at 205-996-6540.

Figure 1. Flow Chart of Activities, Disclosures, and Leave Requests

Flow Diagram

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See the UAB Enterprise Conflict of Interest and Conflict of Commitment Policy, Section 3.11 of UAB Faculty Handbook and Procedures, UAB Enterprise Code of Conduct, and HR 128 for originating policy.

UAB affiliated entities, known collectively as UAB Enterprise, are described in Section 1 of the UAB Enterprise Conflict of Interest and Conflict of Commitment Policy. Activities for UAB Enterprise may be IAs or PPSAs.

See Section 5-A of the UAB Enterprise Conflict of Interest and Conflict of Commitment Policy and the Policy Concerning Use of UAB Resources by External Entities.

Although a publisher (e.g., journal, book, etc.) may be commercial entity, manuscript review qualifies as a PPSA if the content is solely determined by a nonprofit/philanthropic entity, professional society, or professional association.

Activity is excluded as a PPSA if fiduciary responsibilities for the external entity are in conflict of interest with UAB.

Activity is excluded as a PPSA if affiliated to the external entity by academic appointment (e.g., adjunct, visiting, etc.).

A department, school, college, or UAB Libraries may require submission of a time off request of Professional Leave for Internal Activities or other UAB-related activities performed outside of UAB to manage missed clinical, teaching, or other assignments.

If cumulative days of External Activity Leave exceed the limit 20 days per year, then Personal Holiday and/or Vacation must be used (see HR 128).

A Notice of Professional Public Service Activity is required if an Investigator receives renumeration of $5,000 or more per year from a single entity in the previous 12 months (excluding those activities performed for federal, state, or local government agencies) OR renumeration of any amount from a foreign entity.