Summary Crosswalk of Outside Work Policy Changes

The Summary Crosswalk of Outside Work Policy changes provides a high-level overview of the updates to MSU’s Outside Work for Pay policy and MSU’s new Conflict of Interest and Conflict of Commitment Identification and Disclosure Policy. A chart including 8 categories is included, along with a short list of what is not changing.

#	Policy Provisions	Outside Work for Pay Policy	New Policy	Rationale
1	Policy Name	Outside Work for Pay (OWP)	Conflict of Interest (COI) and Conflict of Commitment (COC) Identification and Disclosure The current OWP policy is combined with the existing financial COI policy into one policy.	Regulatory Requirements: For example, NSPM-33 (National Security Presidential Memorandum-33) directs research agencies and institutions to develop practices for disclosing information to assess COI and COC’s.
2a	Terminology	Outside Work for Pay Activities requiring approval. Only includes paid activities	Outside Activities and Conflict of Commitment Activities requiring approval. Now includes paid and unpaid activities.	Revising the definition to ensure compliance with regulatory standards, for example, NSPM-33 defines COC to include conflicting commitments of time and effort. Unpaid activities come with a time commitment.
2b	Terminology	Normal Scholarly Activities Activities exempt from approval	Scholarly Activities Activities exempt from approval	Removed the word “normal”.
3a	Applicability: Who is Covered	All faculty members (tenure system and fixed term) defined as the rank of instructor through professor.	Updated definition: All paid faculty members identified as Ranked Faculty in the Academic Hiring Manual University Approved Positions/Ranks.	While there is no change in coverage, the new definition clarifies the employment categories of ranked faculty that are covered. Faculty that are covered, for example, research faculty, HP faculty.
3b	Applicability: Who is Covered	Executive managers	Executive managers	No change
3c	Applicability: Who is Covered	Academic administrators (e.g., deans, department chairs, and school directors).	Academic administrators	No change
3d	Applicability: Who is Covered	New category	Investigators: The Project Director or Principal Investigator and any other person responsible for the design, conduct, or reporting of research, regardless of title or position, or if identified in the federal award as a Covered Individual.	For regulatory requirements, there may be those designated as Investigators that do not fall under the Faculty definition, and they must comply with COC requirements.
4a	Applicability: When Covered	Academic Year Faculty (9-month) faculty required to only disclose Outside Work for Pay in non-duty period (May 16-August 15).	Academic Year Faculty (9-month) faculty required to obtain approval for Outside Activities in duty period and non-duty period (May 16-August 15).	Activities may span past a non-duty period therefore should be assessed for potential COC with the other outside activities. Activities must be disclosed on federal disclosure forms per requirements of federal agencies such as NSF, DOD, NIH. (Other support, biosketch).
4b	Applicability: When Covered	AY Non-Duty period outside work does not count against the 4 day/month average	No change	No change
5	Procedural Changes	Unit Administrator & Dean/Head of MAU review and approval required.	Unit Administrator & Dean/Head of MAU review and approve and consult with the Office of the Provost and Office for Conflict and Disclosure Management (CDM) if needed.	Additional support to Unit Administrators in navigating the policy and regulatory requirements.
6	Definitions	Definitions included: Outside Work Work Pay Conflict of Commitment (in footnote)	All new definitions. Definitions section expanded and includes the following for example: Conflict of Commitment Covered Individual Duty Period Entity Institutional Responsibilities Outside Activities Scholarly Activities Colleges to provide specific examples for their faculty for Outside and Scholarly Activities.	Definitions created to comply with new University policy template and federal regulations. College specific examples provide better clarity.
7	Involvement of Students and Staff	The involvement of students and staff required disclosure and potential monitoring.	New section added to guide decisions on whether to involve students and staff. If students and staff are to be involved, the arrangement requires prior approval from: the Covered Individual’s department or unit head, the student's faculty advisor or the dean of undergraduate or graduate education, the Department of the Office for International Students and Scholars (if the student or staff is on a visa), and/or the staff member’s direct supervisor.	To ensure full disclosure so that appropriate individuals are aware, and that safeguards can be put in place to prevent conflict situations.
8	Time for Outside Activities	All approved outside work for pay and overload pay assignments for the faculty member will not exceed a total average of four (4) days a month. Any portion of a day during which outside work for pay is conducted is considered a "day" for purposes of the four day per month limit.	Outside Activities are still to not exceed a total average of four (4) days a month. A “day” is equivalent to a standard workday (e.g. 8 hour day) of the Covered Individual.	Updated the definition of a “day” based on benchmarking and stakeholder feedback.

 

What is not changing?

1. Outside activities that require approval are still those in the general area of professional expertise for which the individual is employed by the University. Activities unrelated to an individual’s institutional responsibilities do not require approval or disclosure.
2. Units/Colleges review and provide approval for Outside Activities.
3. Formerly known as “Normal Scholarly Activities” that are now defined as “Scholarly Activities” do not require prior approval.
4. Time Limits for Outside Activities.