2022-23 Annual Conflict of Commitment Reporting – APM 671

Academic Personnel

Office of the Vice Chancellor for Research & Creative Activities

To:	Faculty, Deans, Directors, Department Chairs, and Administrative Officers
Re:	Conflict of Commitment and Outside Activities of Faculty Members

Dear Colleagues:

We are writing to remind you of prior approval and reporting requirements related to outside professional activities and how to comply with UC policy as described in Academic Personnel Manual 671 (APM-671).

APM-671 (along with your School’s Implementation Procedures) provides faculty with the framework to manage potential conflicts of commitment as they balance University obligations with outside activities. Outside professional activities, both compensated and/or uncompensated, are defined as those activities that are within a faculty member’s training and expertise that form the basis of the individual’s qualifications for University appointment, but are performed for a third party. A conflict of commitment may occur when a faculty member’s outside activities interfere with their professional obligations to students, colleagues, or the University as a whole.

All eligible faculty members should use the UC Outside Activity Tracking System (OATS) to request prior approval and report effort for outside activities. To access UC OATS, please go to the Academic Personnel Office OATS webpage and sign in with your UCLA Logon ID and password. Links to video tutorials and user guides are available on the UC OATS webpage, which may be accessed through the Academic Personnel Office OATS webpage as well.

Eligible Faculty Members

All faculty members participating in the Health Sciences Compensation Plan (HSCP) in all professorial series (Regular, In-Residence, Clinical X, Health Sciences Clinical, Adjunct, Visiting, and Recall) at all ranks (Instructor, Assistant, Associate, and Professor) are required to report their outside professional activities regardless of percent of full-time effort (including those on approved leave with pay and sabbatical). Deans and Full-Time Faculty Administrators with an underlying faculty appointment in HSCP are also covered under this policy, but are also subject to the provisions in APM-240 (PDF) and APM-246 (PDF). Faculty members who were on approved leaves without pay, should contact their Dean’s Office for reporting requirements.

Outside Activities Categories

Outside professional activities are separated into three categories based on the extent to which they are likely to constitute conflicts of commitment, whether they are compensated or uncompensated:

Type	Conflict Level	Examples of Outside Activities	Requires Prior Approval from VC-AP Before Engaging in the Activity	Requires Annual Reporting
Category I	Most likely to create a conflict of commitment	• Consulting for for-profit entities, for government agencies, for non-profit entities, for non-profit health or education-related organizations, consulting or testifying as an expert or professional witness, consulting under the auspices of UC • Serving on a board of directors outside of the University • Providing or presenting a workshop for industry • Additional University-compensated teaching	Yes	Yes
Category II	Lesser potential for a conflict of commitment	• Provide outside consulting services or referrals or engaging in professional practice as an individual or through a single member professional corporation or sole proprietorship • Serving on a board of directors outside of the University • Providing or presenting a workshop for industry • Additional University-compensated teaching	No	Yes
Category III	Unlikely to raise a conflict of commitment	• Reviewing manuscripts • Attending and presenting talks at university conferences • Developing scholarly or creative works	No	No

Per UCLA policy on the “Requirement to Submit Proposals and to Receive Awards for Grants and Contracts through the University” and the UC policy on which it is based, proposals for research support should be submitted through UCLA. Requests for exceptions require the prior approval of the Vice Chancellor for Research and Creative Activities as well as the Vice Chancellor for Academic Personnel. All requests for exceptions for permission to submit research proposals through an outside entity are to be submitted to Vice Chancellor Roger Wakimoto (Research), in care of Associate Vice Chancellor Ann Pollack. Upon receiving approval from Vice Chancellor Wakimoto, faculty will also need prior approval from Vice Chancellor Michael Levine (Academic Personnel) before engaging in the outside professional activity.

Prior Approval and Reporting Requirements

In an effort to assure accountability in our public university, eligible faculty are required to: 1) seek prior approval from the Vice Chancellor for Academic Personnel before engaging in any Category I activities, 2) obtain prior approval from the Department Chair before involving a student in an outside professional activity, and 3) submit an annual report of all Category I and II outside professional activities, both compensated and/or uncompensated. Even if there are no Category I or II activities to report, faculty must still submit an annual report certifying that they did not engage in any Category I or II outside activities.

Eligible faculty are required to report their outside activities in UC OATS and certify their activities for fiscal year 2021-22 (July 1, 2021 – June 30, 2022) by September 30, 2022. The David Geffen School of Medicine Implementing Procedures are available as well as FAQ’s (PDF). The School of Dentistry’s Implementation Procedures can be found on the School’s Forms and Letters website under Compensation Plan Documents. Department chairs/Deans must review these reports in a timely manner and shall consult with the dean or the Academic Personnel Office about any concerns.

This summer the Academic Personnel Office has added on-screen assistance prompts to UC OATS to help faculty complete their Annual Certifications. These prompts appear when you log in to UC OATS. You may also call up this guidance by clicking on the blue question mark in the bottom right corner of the OATS application. Faculty who do not want assistance can close these prompts or just ignore them.

In addition to to fulfilling these Conflict of Commitment requirements, faculty have other reporting obligations. Under California and Federal Conflict of Interest regulations and policies, faculty are required to disclose personal financial interests including equity, income, and travel related to extramurally supported research. Additionally, most federal agencies require that proposals for extramural research support include disclosure of all current and pending research support, and professional effort, which may not exceed 100%. Outside professional activities that are approved by or allowed by the University may also have to be reported to federal or other granting agencies for prior approval or as required by the terms of the award. The UCLA website on “Foreign Engagement” contains useful information about reporting outside activities to research sponsors, including what must be disclosed. This general guidance is applicable to activities that take place at both domestic and foreign organizations. Specific guidance about individual contracts and grants should be sought from the campus Office of Contract and Grant Administration.

Thank you in advance for your compliance.

Sincerely,

Michael S. Levine Roger Wakimoto

Vice Chancellor for Academic Personnel Vice Chancellor for Research & Creative Activities