A. What is an Outside Activity?

“Outside activity” is defined in the University policies on conflict of interest. It generally means any activity you do for an entity other than the University that is not part of your assigned duties or annual assignment.

B. What is a Conflict of Interest?

“Conflict of interest” is defined in the University policies on conflict of interest.
According to Florida Statutes, a conflict of interest means a situation in which regard for a private interest tends to lead to disregard of a public duty or interest.

An employee’s primary duty is to the University and to maintain the highest ethical and professional standards. An employee’s outside activity must not conflict, or appear to conflict, with the employee’s obligations to the University.

C. What is a Conflict of Commitment?

A conflict of commitment can occur when an employee engages in an outside activity that interferes with the employee’s assigned duties or responsibilities (e.g., involves frequent or prolonged absences from the University on non-University business or activities that engage a substantial portion of the time an employee is expected to spend on assigned duties or University-related activities).

D. What is the OA/COI Form and where can I find it?

The OA/COI Form is the electronic tool that employees use to disclose outside activities and financial interests.

Login to myhr.fiu.edu and go to the “Employee” home page. Once there, you will see the Outside Activity Form tile. By clicking on the tile, you will land on the OA/COI Form. You can also access the form at my.fiu.edu under your Employee profile.

E. Who is required to complete the OA/COI Form?

All full-time and part-time faculty and staff are required to complete the OA/COI Form whether engaged in an outside activity or not. This requirement also applies to student employees engaged in sponsored research.

Florida Statute Section 1012.977 requires all faculty and staff who are engaged in the design, conduct, or reporting of research to disclose to the University and receive a determination from the University that their outside activity or financial interest does not affect the integrity of the University. That determination must be made prior to their engaging in said activities.

F. Is it a requirement for all faculty and staff employees to complete this reporting whether they believe they have a conflict of interest or not?

Yes.

G. Are student employees also required to disclose any activity related to OA/COI?

Yes, if the student is engaged in the design, conduct, or reporting of externally funded research.

H. I am a new faculty member and have ongoing grants and work that needed to be finalized. Do I need to disclose these and when should I do that?

Yes, you must complete the OA/COI Form and disclose any ongoing research, work, or other outside activities.

New employees must disclose after accepting an offer of hire or within 30 days from the date of hire unless the date of hire coincides with the annual disclosure period.

I. Why do I need to complete the OA/COI Form?
Disclosures are required by state and federal law to ensure conflicts of interests are appropriately addressed by the University. By completing the OA/COI Form, you help to ensure that FIU’s academic, research, and administrative affairs are conducted with the utmost integrity and in compliance with all legal requirements.

J. I do not have any activities to report. Do I still need to complete the OA/COI Form? If yes, how do I complete the form?

Yes. See this section near the bottom of the OA/COI Form: I have no Outside Activities to report.

K. In my Submission History on the portal, what does Nothing to Report mean under Status?

The status will indicate Nothing to Report if you answered Yes in this section of the OA/COI Form: I have no Outside Activities to report, and then clicked on “Certify” in the Outside Activity/COI Form Acknowledgement.

L. What happens if my OA/COI disclosure is denied?

If the activity is denied, then it becomes a prohibited activity that should not be engaged in while employed at FIU. Should you have any questions, please contact any of the individuals in the approval/denial process for more guidance or information. Engaging in a prohibited activity can lead to disciplinary action up to and including termination.

M. Who else sees this information at the University? How am I ensured that my private life is not disclosed to others?

The information will be reviewed by the designated approvers in your business unit, the Office of Research and Economic Development (ORED) if research related, and Employee & Labor Relations. The information disclosed will be reviewed to ensure compliance, the disclosed activity will be approved, modified, or denied, and then the information disclosed remains in the employee portal. Unless there is a specific public records request to view a disclosure, your information will not be shared.

N. When is the deadline to the submit the OA/COI Form? Do I only need to fill it out once a year?
You must complete the OA/Form during the annual disclosure period even if you are not engaged in or planning to engage in an outside activity. Look for an email communication from the Division of Human Resources and the Office of Research and Economic Development announcing the annual campaign which is typically done in the fall.

In addition to the required annual disclosure, you are also required to complete an OA/COI Form to disclose a new outside activity OR when there is a significant or material change in a previously reported outside activity.

If you are participating or will be participating in a research project at or on behalf of the University, you must complete the OA/COI Form.

O. What time frame does my annual disclosure cover?

The annual disclosure covers the entire fiscal year (July 1– June 30).

P. What about any outside involvement during the last half of last year that is not happening at the present time?

If you have engaged in an outside activity as of July 1, you should disclose it even if you are not currently engaged.

Q. What happens if an employee does not complete the OA/COI Form by the specified deadline or does not complete it at all?

If engaged in research, Florida Statute Section 1012.977(3) requires the following: “An employee who has failed to disclose any outside activity or financial interest as required by subsection (1) shall be suspended without pay pending the outcome of an investigation which shall not exceed 60 days. Upon conclusion of the investigation, the university or entity may terminate the contract of the employee.”

If not engaged in research, the University will place a letter of non-compliance notification in the employee file which will be considered during the employee’s annual evaluation. If an employee consistently fails to disclose, other disciplinary actions may be taken up to and including dismissal.

R. When serving on a non-profit board, how should I indicate the hours/days/etc.?

You should consider the meeting dates and any other time you are engaged in this activity. Providing accurate and complete information will facilitate the determination of whether an activity can be approved or not.

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A. Am I able to view my OA/COI disclosures from previous years?

Yes. Employees and approvers have the ability to view previous disclosures submitted through the PantherSoft HR system.

B. Does the system allow faculty to review previous and still valid OA/COI Forms? If yes, can they be renewed/amended with new details if needed? Is there an option to resubmit a previous disclosure for recurring annual activities (e.g., book royalties)?

A new set of questions was released for the 2021/2022 cycle. In the future, you will have the ability to copy a previous disclosure.

C. Can you re-disclose at any time in the portal?

Yes. You can report any outside activity at any time in the portal. There are also no limits on how many OA/COI Forms can be submitted.

D. Who can I contact with questions about the portal?

You can direct general questions about OA/COI reporting to the Division of Human Resources Service Center at 305.348.2181.

E. How can I check that my OA/COI Form is filled out correctly?

The electronic form has required fields that will guide you through the process. All the appropriate fields must be completed before the system allows you to “certify” your form. If more documentation is needed, the designated approvers in your business unit will contact you.

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A. Where do I get more information regarding outside activities and conflict of interest?

BOT-UFF Conflict of Interest/Outside Activity policy
Conflict of Interest policy #1710.075
Conflict of Interest in Research policy #2370.005
Working at FIU – FIU Human Resources
Office of Research & Economic Development (ORED)
FIU Develop

B. Where can I access the conflict-of-interest webinar recordings?

The webinar recordings, the Power Point slides, and the Inside/Outside Activity Decision Trees will be available on FIU Develop. Direct course links:
Conflict of Interest Webinar for Approvers
Conflict of Interest Webinar for Faculty
Conflict of Interest Webinar for Admin & Staff

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A. How can I determine whether my activity is an inside activity or an outside activity?

The OA/COI team has prepared a decision tree for faculty and another one for staff which can be found on FIU Develop. Follow the applicable decision tree. Note that if your “inside” activity involves a foreign entity or you are engaged in sponsored research for FIU, you need to answer sections 1 and/or 2 of the OA/COI Form.

If you are engaged in sponsored research for FIU, you must compete the research section of the OA/COI Form, section 1. The questions and instructions in section 1 will cover the items that you need (or don’t need) to report. See also the FAQs on Sponsored Research Activity below. Additionally, both inside and outside activities with foreign entities should be disclosed in section 2 of the OA/COI Form.

B. Serving (unpaid) on editorial boards of journals is a part of the professional service and academic growth for faculty. Service is a part of the annual assignment. Do these activities still need to be reported?

It does not need to be reported in sections 3-13 of the OA/COI Form because it is considered the faculty member’s assigned duties. However, if the employee is engaged in research, he/she should complete section 1 of the OA/COI Form and answer the questions there. Section 2 should also be completed if the service is for a foreign editorial board.

C. Do any of the OA/COI requirements apply to spouses or immediate family members?

While only FIU employees are required to complete the OA/COI Form, there are four sections of the OA/COI Form that seek information about spouses, children or other family members:

Section 1 asks for information about you, your spouse, and dependent children

Section 9 asks for information about you, your spouse, and children

Section 14 and Section 15 ask for information about you or a member of your immediate family (as defined in the Stark law).

D. Our university has a MOU with a partner university and an honorarium is offered for the delivery of a course or lecture. Is an OA/COI Form needed given the MOU has already been approved?

Based on the decision tree developed for faculty, the answer is no.

E. If I collaborate with a professor at a foreign university, do I have to disclose that?

Yes, if it is not in furtherance of an agreement that is signed between FIU and the foreign university. You need to disclose this information in section 2 of the OA/COI Form. In addition, if you are engaged in externally funded sponsored research for FIU you should answer section 1 also.

Section 2 also addresses collaborations. It asks for disclosure in the following situation: You have appointments, affiliations, activities, interests, or collaborative projects (whether paid or unpaid and even if described as honorary, courtesy, adjunct or other similar description) with any foreign university or other foreign entity or foreign government, including any involvement in any talent programs (e.g., programs in which you have been recruited by a foreign university, entity, or government).

F. Is being a part of an international professional group (such as registering for an international conference for presentations of research and scholarship) considered a conflict?

See the answer to E above.

G. Do I have to disclose public speaking?

Based on the decision tree developed for faculty, the answer is no. However, if the public speaking is not part of the faculty assignment, the faculty member would have to disclose the activity.

H. If I think that the activity I am doing is an inside activity, but I am getting an honorarium, or the activity is taking a large time commitment and I would like to report to make sure, which section should I use to report this?
Based on the decision tree developed for faculty, an honorarium would generally be considered an inside activity. If the honorarium is NOT part of the faculty assignment, then it is an outside activity and should be disclosed.

As noted on the faculty decision tree, if there is some aspect to the activity that might prevent a reasonable person from concurring that the activity is part of the employee’s FIU job (e.g., high compensation, high time commitment, etc.), then the activity should be reported.

Depending on the facts of the activity, it could be reported in several places on the OA/COI Form including:

Section 4: Any compensated Outside Activity related to your expertise

Section 13: Any Outside Activity that you have not already reported above including an activity that involves frequent or prolonged absences from the University on non-University business or activities that engage a substantial portion of the time you are expected to spend on your assigned duties or University-related activities.

You also need to complete section 2 if this activity involves a foreign entity. See the answer to E above.

WHEN IN DOUBT, DISCLOSE!

I. Does publishing a paper which has coauthors from foreign universities need to be disclosed?

Yes. See the answer to E above.

J. If I provide editorial services for a journal using the FIU computer, do I need to disclose?

No unless this is for a foreign entity. Refer to the decision tree for faculty. If it is for a foreign entity, then you need to disclose in section 2 of the OA/COI Form and include information about the use of University resources to conduct this activity (including an FIU computer).

K. Does having a second job in something completely unrelated to my FIU assigned duties, such as owning real estate or a hotel facility, need to be disclosed? If so, which section applies?

Based on the decision tree for faculty or staff, you would have to disclose because it is not an inside activity. Depending on the facts of the activity, the following sections of the OA/COI Form could apply:

Section 4: Any compensated Outside Activity related to your expertise

Section 9: You, your spouse or child(ren) serve as an officer, director, partner, proprietor or have a material interest (more that 5% ownership interest) in a business entity that seeks to do business with FIU

Section 10: You hold an employment or contractual relationship with a business entity that seeks to (i) do business with FIU, (ii) enter into a contract with FIU, or (iii) engage in activities that may conflict with FIU’s interests

Section 13: Any Outside Activity that you have not already reported above including an activity that involves frequent or prolonged absences from the University on non-University business or activities that engage a substantial portion of the time you are expected to spend on your assigned duties or University-related activities

If you are engaged in externally funded sponsored research for FIU, you would have to disclose in section 1 of the OA/COI Form because of Florida Statute Section 1012.977. Note that the Florida Statute questions are located toward the bottom of section 1.

L. If I sold real estate or engaged in property management on a part-time basis, on my personal time, would I need to disclose?

Based on the decision tree for faculty or staff, you would have to disclose because it is not an inside activity.

M. Sometimes I feel an outside activity may be hard to separate from off-campus service. For example, if I am asked to review some government reports or reports from NGOs as an independent reviewer (paid or unpaid), do I have to report that?

Use the decision tree for faculty to determine whether any of these activities are inside (i.e., they are part of your assignment) or not. If these are outside activities, then you must disclose them.

WHEN IN DOUBT, DISCLOSE!

N. Does working with community partners on a grant-related project need to be disclosed?

If the grant-related project is being managed by the Office of Research and Economic Development and your work with those community partners is part of said grant, then no. Based on the decision tree for faculty or staff, this would not need to be disclosed because it is part of your assigned duties.

O. If I am an employee of FIU, but my position is funded by grant funding, is this something that I as an employee would have to declare?

Based on the decision tree for faculty or staff, this would not need to be disclosed because it is part of your assigned duties.

P. If I am reviewing papers for journals, do I need to disclose?

Based on the decision tree for faculty, this would not need to be disclosed because it is part of your assigned duties. If there is some aspect of the work which would prevent a reasonable person from concurring that the activity is part of the employee’s FIU job (e.g., high compensation, high time commitment, etc.), then the activity should be reported.

Q. I am the owner of a business in Texas that has nothing to do with my position at FIU, and I do not run it myself. Do I need to disclose it to FIU?

Based on the decision tree for faculty or staff, you would need to disclose this outside activity.

R. What if someone works for a network marketing company (absolutely nothing to do with FIU) in their spare time?

Based on the decision tree for faculty or staff, you would need to disclose this outside activity.

S. I am an FIU employee and a graduate student (Ph.D. candidate) and am currently in the process of completing my dissertation study. I have IRB approval for my degree and study-related qualitative research. My major professor is listed as the PI to a grant that I am working on. Do I need to fill out the OA/COI Form since I am conducting student dissertation research?

It would appear that you are working on a grant for which your major professor is the PI; therefore, you are engaged in sponsored research at FIU and should complete the OA/COI Form.

T. Should FIU employees who also work for a firm as tutors for middle school students disclose?

Based on the decision tree for faculty or staff, this is not part of your assignment and should be disclosed.

U. I serve as an adviser for a student group on campus. Is that considered an inside activity?

Based on the decision tree for faculty or staff, this could be part of your assignment and is not an outside activity you would need to disclose.

V. If I receive extra compensation from FIU to engage in an activity, do I have to fill out an OA/COI Form?

No because FIU is paying for the activity.

W. I am a member of the music faculty. I perform at a series of musical events. Do I need to submit an OA/COI Form?

Based on the decision tree for faculty, you do not have to disclose because it should fall within the scholarship/creative activity portion of your assignment.

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A. I understand that the Florida statute (Fla. Stat. Section 1012.977) only applies to externally funded sponsored research activity. What is the definition of externally funded sponsored research?

Externally funded research is defined as research projects managed through the Office of Research and Economic Development.

B. Does this apply to postdoctoral associates?

This applies to all employees, including postdoctoral associates.

C. If I am analyzing internal FIU data for my program to identify program improvement areas, is that considered a conflict of interest under section 1 of the OA/COI Form?

No because that is an inside activity.

D. Does the “use of expertise” apply to serving as an unpaid peer reviewer for journal articles?

Yes, that should be reported.

E. I have a research project that is not funded or managed through FIU. This is not University research. Do I need to disclose this?

Yes. You should disclose this in section 3 of the OA/COI Form which asks for information regarding any research project that is not on behalf of the University or research resources or funding you receive through an entity other than FIU.

Section 2 should also be completed if the research project, research resources or funding involve a foreign university or other foreign entity or foreign government.

F. What financial interests should be disclosed? For example, should an employee report stocks outside of their retirement accounts?

Yes, stocks outside of your retirement accounts should be reported if you are engaged in research. The questions in section 1 of the OA/COI Form pertaining to research provide instructions on what financial interests must be reported and which can be excluded from reporting. For example, that section explains that reporting is required pursuant to Florida Statute Section 1012.977 which defines financial interest that must be reported as follows: “Financial interest is defined as anything of value other than that provided directly by the university or entity.”

The federal regulations also require reporting. If you answer the questions in section 1, it will capture the reporting that is required per both the federal and Florida law and regulations.

G. I have some difficulty in pinpointing the exact location (foreign or domestic) of publishers as they have multiple offices for different aspects of publishing. What should I do?

When you report, you can provide an explanation in the General Comments section. If further information is required from you, someone will reach out to you.

H. If an employee does not comply with the Florida Statute reporting requirements, is he/she placed on a 60-day paid or unpaid leave?

Unpaid leave. Florida Statute Section 1012.977(3) provides the following: “An employee who has failed to disclose any outside activity or financial interest as required by subsection (1) shall be suspended without pay pending the outcome of an investigation which shall not exceed 60 days. Upon conclusion of the investigation, the university or entity may terminate the contract of the employee.”

I. Is the Florida statute only for those working on grants, or does it include doctoral students working on their own research?

At this time, Florida Statute Section 1012.977 applies to all University employees with externally funded research engaged in the design, conduct, or reporting of research who must disclose to the University and receive a determination from the University that their outside activity or financial interest does not affect the integrity of the University. That determination must be made prior to their engaging in said activities.

J. Are grant administrators considered engaged in research activities?

If the grant administrator is not engaged in the design, conduct, or reporting of research, then no. For example, if you are an accountant in a department keeping track of grant financials, then you are not engaged in the research and do not need to report your financial interests or outside activities per the Florida Statute.

K. Are Ph.D. students who are TAs or RAs allowed to own stocks or invest in stocks?

If the student owns stock and the student is engaged in sponsored research, then the student should report the stock, per the instructions in section 1 of the OA/COI Form.

L. Would I be considered engaging in research if I am a subject/respondent as part of a research study?

You would have to be engaged in the design, conduct, or reporting of research. Generally, this would mean the PI/Co-PIs, RAs, and other personnel in the project. Subjects/participants generally do not meet those criteria.

M. Do I have to list each and every item of a private investment portfolio even when the companies involved have no connection to the work I am doing, and update it every time a trade happens? What about privacy rights?

Yes. Florida Statute Section 1012.977 defines “Financial interest” as “anything of value other than that provided directly by the university or entity.” As such, you would need to report per the Florida statute. You may also need to report per the federal regulations depending on the value of the financial interests. The above disclosures are required if you engage in research at FIU. You would answer all the questions in section 1 of the OA/COI Form and those questions will capture the financial interest reporting required from you.

N. Should my personal stocks be reported as an outside activity?

You should report those as a financial interest if you are engaging in research for FIU or seeking to engage in research for FIU. You would complete section 1 of the OA/COI Form and that is where the disclosure of stocks takes place. Note that Florida Statute Section 1012.977 defines “Financial interest” that must be reported as including “anything of value other than that provided directly by the university or entity.” Thus, the definition is broad.

O. Would federal U.S. savings bonds need to be disclosed as assets under non-publicly traded entities?

The definition of “Financial interest” under Florida Statute Section 1012.977 states that it includes “anything of value other than that provided directly by the university or entity.” As such, you would need to report the bonds given that broad definition. However, this disclosure is required only if you are engaging in or seek to engage in research at FIU and therefore are reporting in section 1 of the OA/COI Form.

P. I don’t understand why private investments need to be disclosed. Am I misinterpreting what has been said?

The definition of “Financial interest” under Florida Statute Section 1012.977 states that it includes “anything of value other than that provided directly by the university or entity.” The reporting is required so that the University may determine if the financial interests of employees impact the “integrity” of the University as required by that statute and also if it results in a conflict of interest as required by the federal regulations.

Q. Do the investments need to be disclosed if through a State program, e.g., 403(b) investments?

Not if they are through FIU. See question F above.

R. If I am doing things that have nothing to do with my role (or the expertise that I was hired to use) at FIU, do I need to disclose?

Florida Statute Section 1012.977(2) contains the following definitions: “(a) ‘Financial interest’ includes anything of value other than that provided directly by the university …. (b) ‘Outside activity’ includes anything an employee does for an organization or an individual, other than the university or entity, that is related to the employee’s expertise.” If the outside activity does not meet that criteria then it does not need to be disclosed; however if there is any doubt, please disclose.

S. If I submitted a proposal through ORED and answered the conflict of interest questions on the ePRAF, do I need to answer these questions again on the OA/COI Employee portal?

The questions on the ePRAF are designed to ascertain whether there are any conflicts associated with the specific proposal, when the last date of your disclosure was on the OA/COI portal, whether you have had any material changes since your last disclosure and if you took any required conflict of interest training. The ePRAF is not the official system of record for outside activities or conflicts of interest disclosures. All outside activities and potential conflicts of interest need to be disclosed on the OA/COI portal located on the HR website.

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A. I am a faculty member in the College of Business. I do business consulting for youth programs throughout the state (at an hourly rate or at no charge). Since I only do this consulting when I am not teaching at FIU, does this need to be disclosed as an outside activity?

Yes. This consulting work is an outside activity and needs to be disclosed (whether compensated or uncompensated). If you are engaged in sponsored research for FIU, you are also required to make additional disclosures regarding outside activities and financial interests. See section 1 of the OA/COI Form.

B. I work in the Office of Financial Aid. I am also a paid consultant for a company that helps high school seniors apply for college scholarships. Do I need to disclose my consulting work as an outside activity?

Yes. This consulting work is an outside activity and needs to be disclosed.

C. At my FIU job, I review scholarship applications for completeness and answer questions from applicants, but I do not have the authority to make decisions on who receives FIU scholarships. Do I need to disclose my consulting work with a company that assists students with scholarship applications?

Yes. Your position in the Office of Financial Aid creates a potential conflict of interest. It would be difficult for you to be objective with respect to any scholarship applications prepared by this company and submitted to FIU for consideration. There is also a potential for you to misuse your public position (i.e., your FIU job) or disclose information to clients of the company that is not available to other students applying for FIU scholarships. This would be a violation of Florida ethics laws.

D. I am a faculty member in the College of Engineering and volunteer as a consultant for small engineering firms. Do I need to report this since I am not being paid?

Yes. See section 5 of the OA/COI Form which addresses uncompensated Outside Activity related to your expertise.

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A. I own and operate a wine store with a business partner. My business partner handles the day-to day operations. I only work at the store at night and on the weekends (not during my FIU work hours). Since this business in unrelated to my position at FIU, do I need to disclose this?

Yes. Owning or operating a private business is an outside activity that needs to be disclosed even if it seems like it has nothing to do with your responsibilities at FIU.

I understand that FIU wants to consider my time commitment to make sure this business is not affecting my FIU job performance. But what possible conflicts of interest could exist?

There are various situations that could create a possible conflict of interest. To name a few:

• Using University employees or students to help in this business (whether paid or unpaid)
• Using University facilities, equipment, supplies, services, or other resources to advertise or promote this business
• Doing business with the University

My business partner, a certified sommelier, teaches classes at the store and connects his students with job opportunities in the restaurant business. I am not involved in any way with these activities. Do I need to disclose this?

Yes. Even though you may not be personally involved, you have an employment relationship with a business entity that may be engaging in activities that conflict with University activities (e.g., FIU hospitality programs). See section 10 of the OA/COI Form.

B. I am a graduate student and work as a paid teaching assistant (TA). I own a start-up company with my best friend (not an FIU employee or student). We are the only owners and employees of this company and it is a Florida company. Do I need to disclose this company as an outside activity?

Yes. As a paid teaching assistant, you are an FIU employee. You have an ownership interest and employment relationship with this company, so it needs to be disclosed as an outside activity.

After this semester, I will be starting a new position in a research lab on campus. Will this new position affect my disclosure obligations?

Yes. As a lab employee, you will be engaged in sponsored research for FIU and required to make additional disclosures regarding outside activities and financial interests. See section 1 of the OA/COI Form.

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A. I am a faculty member, and I serve on the board of directors of a private company based in another state that provides services that are related to my FIU expertise. I receive no compensation (salary or expense reimbursement) and have no ownership interest in this company. Do I need to disclose this as an outside activity?

Yes. Serving on a board of directors or holding a management position in a business entity needs to be disclosed as an outside activity (whether your role is compensated or uncompensated). See section 4 and section 5 of the OA/COI Form.

B. What if this company was not related to my FIU expertise? Would I still need to disclose this as an outside activity?

Yes. Your position in this company may involve a significant time commitment that could interfere with your FIU responsibilities. See section 13 of the OA/COI Form. If you are engaged in sponsored research for FIU, you are also required to make additional disclosures regarding outside activities and financial interests. See section 1 of the OA/COI Form.

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My son-in-law owns a treatment center, and I am a faculty member at the HWCOM. How do I disclose this?

In addition to the disclosures required for any employee with a compensated outside activity, you also need to complete two sections of the OA/COI Form specifically related to entities that provide health care goods and services. These disclosures include your interests and interests of a member of your Immediate Family (as defined by the Stark law and includes a son-in-law). These sections must be completed if you are an employee at the College of Medicine.

Section 14: You or a member of your Immediate Family have an ownership interest in an entity which provides health care goods or services

Section 15: You or a member of your Immediate Family have an independent financial relationship (compensation or debt) with an entity, other than with FIU, which provides health care goods or services

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A. Does working with a local chapter, society, or organization as part of their board of directors or as a committee chair require disclosure even though it’s volunteer work and not compensated?

Yes. If this activity is related to your expertise, you should disclose in section 5 of the OA/COI Form. If this activity is not related to your expertise, it should be disclosed in section 13 of the OA/COI Form because it may involve a conflict of commitment.

B. I volunteer (no compensation) for a Florida professional association that provides networking opportunities that benefits my FIU role. Is this an activity that needs to be disclosed?

If this activity is part of your assigned duties at the University you do not need to disclose it. Otherwise, it needs to be disclosed.

C. For the purposes of disclosure reporting, is volunteering for another state agency considered “working” for the agency?

While it will not be considered working, this volunteering is an outside activity that should be disclosed.

D. If I volunteer at my church on Sunday, do I need to disclose this?

No unless it interferes with your assigned duties and could result in a conflict of commitment. See section 13 of the OA/COI Form.

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I want to teach during the summer when I am not assigned to FIU. Why would I have to report an outside activity?

You must disclose any teaching that you conduct during summer for a number of reasons. First, if you are engaged in sponsored research, Florida Statute Section 1012.977 requires such disclosure. Second, even if you are not engaged in sponsored research, you need to disclose if doing teaching with a foreign institution. Third, the University needs to know if you contemplate using any FIU logos or other trademarks. Finally, the University needs to know if the University has any licenses on the intellectual property.

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A. I am 9-month faculty member, do I need to report any activity/work during the summer?

Yes. Regardless of whether the outside activity occurs during a University assignment or appointment, an employee must disclose the outside activity and receive approval from all approvers before engaging in the activity.

B. Do I need to disclose if I receive Extra State Compensation?

No. This is an inside activity.

C. Do I need to disclose if I work at another unit in FIU beyond my assignment or duties?

No. This is an inside activity.

D. If a FIU grant administrator engages in grants-related activities with community nonprofits, does this have to be disclosed?

Yes.

E. I have a part-time job on the weekends outside of my normal working schedule. Would I select section 13 to disclose this?

If the activity does not qualify under the other sections of the OA/COI Form, you should select section 13. This catch-all question captures any outside activity that you have not already reported in another section of the OA/COI Form.

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