Where can I find more information about Pre-Approval Requests?
Who needs to submit a disclosure?
Answer: All Faculty covered by the Faculty Handbook and all Investigators on sponsored projects. Adjunct Faculty generally are 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 financial or 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 GRAs 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: 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 will Chairs/LAU Heads and Deans have to help them decide whether an activity is or is not acceptable?
Answer: Chairs and Deans will refer to University Policy 4021, the University Policy 2021 Procedures, and to their School or College’s Procedures in deciding whether an activity is acceptable. They will also be able to refer questions to ORIA, Institutional Compliance, and to Human Resources.
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 chairs as reviewers/approvers, 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 outside 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.
Who do I contact if I have other questions?
Answer: Contact rampcoi@gmu.edu.
What are some possible consequences for failure to comply?
Answer: There will be a range of disciplinary actions depending on the severity of the issue. The process would be a similar process for any employee misconduct and would include alerting HR.
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 Mason. Unless 9-month faculty have a separate summer engagement with Mason, policy 4021 does not apply to them during the summer.
Are there special requirements when an Outside Professional Activity is performed at or with a foreign entity?
Answer: Foreign appointments and affiliations need to be disclosed. For activities performed when a faculty member is under contract with Mason, prior approval is required before engaging in the activity.
What are the faculty/chair responsibilities for reporting if we are aware that a colleague is working elsewhere, running a business, teaching elsewhere, or administering grants through external organizations instead of the university?
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 Institutional Compliance or the Office of Research Integrity and Assurance.
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 ORIA and Institutional Compliance, who then review the changes for consistency with the policy. Deans will communicate to their faculty any changes to their collegiate procedure.