I received a message from RAMP that my Disclosure Profile requires action. How do I complete the training it mentioned?
Answer: The required RAMP training is actually an acknowledgment embedded within the Disclosure Profile Update. To complete the required training, (1) log into your Disclosure Profile in RAMP using your GMU SSO credentials, (2) find the the “Instructions and Policies” page of the Disclosure Profile Update, and (3) click the check-box at the bottom of the page in RAMP certifying you have reviewed the information. Please be sure to complete the additional steps in RAMP afterwards to update your Disclosure Profile with any significant financial interests or outside professional activities as appropriate.
Where can I find more information about Pre-Approval Requests (PARs)?
Answer: This one-page summary sheet provides information on what type of activities require a PAR, who needs to submit a PAR, and where to submit a PAR.
Who needs to disclosure Conflicts of Commitment?
Answer: All faculty covered by the Faculty Handbook and all Investigators on sponsored projects. Adjunct faculty are typically not required to submit a disclosure.
What are some examples of possible conflicts?
Answer: Conflicts of Commitment are generally situations in which a researcher is dedicating time to personal activities in excess of the time permitted by institutional policy, or to other activities that may detract from his or her primary responsibility to the institution. The issue here is not necessarily a financially-influenced bias in one’s judgment, but rather whether one’s commitment of time and effort are inconsistent with one’s commitment to the institution and its interests. Some examples of conflicts of commitment include:
- A faculty member dedicating more than the permitted one day per week on personal consulting with a company or companies.
- A faculty member accepting an unpaid position on a company’s Scientific Board of Advisors and having access to and/or divulging confidential information when the company is sponsoring the faculty member’s research.
- A faculty member uses institution resources, including office or laboratory space and secretarial services in support of his or her personal consulting.
Does the policy apply only to faculty? What about graduate researchers or postdocs?
Answer: The policy only applies to GRAs or postdocs if they are Investigators on sponsored projects.
What kind of things am I required/not required to report?
Answer: University Policy 4021 establishes three kinds/levels of outside activities: activities that do not need to be reported; activities that must be reported but do not need prior approval; and activities that must be reported and that require prior approval from your Dean.
What support do Chairs/LAU Heads and Deans have to help them decide whether an activity may or may not create a conflict?
Answer: Chairs and Deans should refer to University Policy 4021, the University Policy 4021 Procedures, and to their School or College’s Procedures in deciding whether an activity is acceptable. They are also able to refer questions to the Office of Institutional Compliance, the Office of Research Integrity and Assurance (ORIA), and to Human Resources. Questions about activities may be emailed to Institutional Compliance and ORIA via [email protected].
How much time/effort will reviewing and approving take? Will it take as much time/effort as setting up a COI waiver?
Answer: The amount of time and effort reviewing and approving will take will vary depending on what is disclosed. Most disclosures will require far less time/effort than setting up a COI waiver. However, there may be others, such as activities involving a foreign talent program, which may require more time and consideration.
Why do chairs serve as intermediate reviewers, rather than HR or others?
Answer: Chairs/LAU heads know what a faculty member’s workload and institutional responsibilities are, and also are aware of disciplinary norms regarding professional activities. For this reason, Chairs/LAU heads are best positioned to evaluate whether an outside activity has the potential to create a conflict of commitment.
Do only Outside Activities for which payment is received need to be reported?
Answer: No, activities need to be reported whether or not compensation is received.
What are some possible consequences for failure to comply?
Answer: There are a range of disciplinary actions that may be taken depending on the severity of the issue, similar to the range of outcomes that result from findings of different types of employee misconduct.
Will the expectations be different in the summer vs the regular academic year for 9-month faculty?
Answer: Yes, the policy only applies to faculty when they are under contract with George Mason. Unless 9-month faculty have a separate summer engagement with George Mason, University Policy 4021 does not apply to them during the summer.
Currently, all Outside Professional Activities associated with a foreign entity requires pre-approval by the college dean, regardless of when the activity occurs. This includes 9-month faculty engaged with a foreign entity during the summer months when they would normally not be required to disclose outside professional activities.
Are there special requirements when an Outside Professional Activity is performed at or with a foreign entity?
Answer: All foreign appointments and affiliations need to be disclosed and pre-approval is required before engaging in these activities.
What are the faculty/chair responsibilities for reporting if we are aware that a colleague has an unreported conflict (e.g., is teaching at another institution)?
Answer: As with any university policy, if a Chair is aware of noncompliance by one of their faculty, they should report the noncompliance to the appropriate office. In this case, noncompliance should be reported to the Office of Institutional Compliance or the Office of Research Integrity and Assurance (ORIA) via [email protected].
What is the process for specifying or modifying a college-level procedure?
Answer: A Dean may change the procedure for their college at any time. They do so by submitting a revised procedure to the Office of Institutional Compliance and the Office of Research Integrity and Assurance (ORIA) who then review the changes for consistency with the policy. Deans will communicate to their faculty any changes to their collegiate procedure.
Who do I contact if I have other questions?
Answer: Contact [email protected].