Outside Professional Work for Compensation (Form 1460)

The Approval Process

Pre-Approval

1. Download and complete the Request for Approval Form 1460.
2. Forward the completed Form 1460 to your department chair* for approval and signature.
3. Chair forwards Form 1460 to your dean/chancellor for approval and signature.
4. Dean/chancellor will forward 1460 to:

   Office of Research
   Attn: Outside Work Requests
   Box 351202
   work1460@uw.edu

5. Contact the Office of Research at work1460@uw.edu or (206) 616-0804 with questions.

*Some schools and colleges have additional approval requirements. Also, certain situations require additional review and/or the establishment of a plan to manage issues such as conflicts of interest. Such situations may also require review and approval by the Assistant Vice Provost for Research Compliance.

Processing

1. The Office of Research verifies that the Form 1460 is complete.
2. The completed Form 1460 is forwarded to the Assistant Vice Provost for Research Compliance for review.
3. If no conflicts are identified, the request is approved, and you and your school or college will receive email notification of approval within three working days of receipt of the completed Form 1460.

Determination

1. If a conflict is present, the Assistant Vice Provost for Research Compliance will determine whether or not a management plan is needed.
2. If a management plan or further information is needed, you or your school or college will be contacted.
3. Final approvals will be considered as soon as possible by the Assistant Vice Provost for Research Compliance following receipt of an acceptable management plan.

Post-Approval

Once final approval is granted by the Assistant Vice Provost for Research Compliance, you and your school or college will receive an email notification of approval within three working days.

Scenarios

I have been invited to present my research at another academic institution for which I would receive a $1,000 honorarium. Does this activity require submission of Form 1460?

No. Invitations to make scholarly presentations, even for compensation (the honorarium), constitute one of several categories of activities that are excluded from the Outside Work Policy. Approval is not required for this presentation. (See “Additional Considerations” below for other exclusions.)

I have been asked to serve on a scientific advisory board for a company for which I would be paid $15,000 per year to attend four day-long meetings. Does this activity require submission of Form 1460?

Yes. Providing consulting services for industry requires prior approval as outside work for compensation. Complete Form 1460 and submit it for review and approval by your department chair and school or college dean or chancellor. If the consulting period falls within a single year (Academic Year is recommended, July 1 through June 30), submit one Form 1460 covering the entire period. If the consulting period spans two or more years, submit one Form 1460 for each year or part thereof.

I referee my child’s sports league, for which I am paid $40 per game. Does this activity require submission of Form 1460?

No. Unless you are involved at UW in athletics, these activities are not considered “professional” activities with respect to your UW position. Prior approval is not required for these activities.

Additional Considerations

Approval is NOT required when any of the following is true:

• You are not compensated in any way (including in kind, waived or assigned compensation) for the outside work;
• The outside work involves contributing professional expertise related to your academic work for scholarly, editorial and advisory bodies, including governmental bodies;
• The work is community service on public commissions or boards of philanthropic organizations;
• Outside work is at the invitation of colleges and universities, and governmental agencies involving:
  • presenting guest lectures
  • delivering scholarly papers
  • serving on review panels
  • participating in accreditation activities

The above activities are not subject to limitations on outside work and do not require prior approval as such. If the activities involve travel, however, approval for travel away from the University must be sought from the appropriate supervisor. This exclusion does not apply to teaching courses for credit or participating in continuing education activities not under the aegis of the University of Washington; prior approval for such activities must be sought.

UW Facilities/Equipment/Resources

De minimis use of University facilities and resources may be permissible for approved Outside Work. For information regarding the University’s Policy on the use of UW facilities, equipment or resources please refer to Administrative Policy Statement 47.2, especially section 3.c.

FAQs

How has the Form 1460 changed?

The Form 1460 itself is still available for downloading and completion as a Word document, but it has been reformatted and the order and wording of some of the questions have been changed. No significant new information is being requested, but it is hoped that the reformatting and the re-wording and re-ordering of some of the questions will make the Form easier to complete and review. The assignment of intellectual property has been removed from Form 1460. Instead, Form 1460 includes a few questions that assess whether or not a present assignment is appropriate for this engagement. How has the 1460 approval process changed? The approval process (routing to your Department Chair and Dean’s Office, then the Office of Research) has not changed. Questions and comments about the Outside Work Policy (Executive Order 57) or Form 1460 may be addressed to work1460@uw.edu.

What University resources are available to Faculty, Librarians, and Staff should their conduct in the performance of outside professional work for compensation be questioned or subject to scrutiny?

University policies governing outside professional work for compensation are intended to support outside work opportunities for Faculty, Librarians, and Staff that may not otherwise be allowable under WA State Ethics in Public Service law. Compliance with University policies governing outside work and conflicts of interest creates a Safe Harbor for Faculty, Librarians, and Staff engaged in approved outside work.

While compliance with University policies in the conduct of outside work is required, the specific activities are considered to be engagements by the individual and not part of the individual’s University responsibilities. As such, University resources, including legal representation, are not generally available to Faculty, Librarians, or Staff whose outside work activities may violate the law, University policies, codes of conduct, or otherwise be questioned or subject to external scrutiny.

Who

Do I need to request approval for my outside work if I have a part-time faculty appointment?

Yes. Time commitment is not the only aspect of outside work that is considered. Form 1460 will also be reviewed for conflicts with UW policies as well as financial conflicts of interest or academic conflicts.

Do I need to request approval for consulting that I have already disclosed in the Financial Interest Disclosure System (FIDS)?

Yes. Your FIDS disclosure is required to initiate the process for assuring that your research or technology transfer activities are not in conflict with the financial interest resulting from your consulting. Your Form 1460 will be reviewed for conflicts with other UW policies and other types of conflicts, such as academic conflicts.

I have a part-time administrative appointment in addition to my faculty position. From whom do I obtain approval?

If the outside professional work pertains to your faculty position, obtain approval from your chair and dean/chancellor. If it pertains to your administrative position, obtain approval from your administrative supervisor.

I am Professional or Classified staff, do I need to fill out an Outside Work request?

Yes, although requests for Professional and Classified staff are not handled by the Office of Research, and therefore you will not fill out Form 1460. Please see Administrative Policy Statement 47.3 for the correct form and instructions on obtaining approval, or contact your immediate supervisor for questions on your department’s approval process.

What

What counts as “compensation”?

Compensation is defined very broadly in the UW policy and includes payments of any kind, equity interests (e.g., stock or options), sponsored or reimbursed travel, and intellectual property. Under the policy, it is still considered compensation even if you waive or assign compensation or if the compensation is in kind.

What is the number of days I am allowed to engage in outside work?

You are eligible for up to one calendar day per week (seven calendar days) of the time you work for the UW. If you are a 100% FTE on a 12-month appointment you are eligible for a maximum of 52 days per year. If you are a 100% FTE on a 9-month appointment you are eligible for 39 days during your nine UW months and 65 days during summer months (104 days total). If you are part-time, then you have your non-UW time available and are additionally eligible for a prorated number of your UW days (i.e., if you are 50% FTE, you are eligible for up to one-half day of UW time per week in addition to your 50% non-UW time.). You may combine multiple partial days to make up full days requested. Travel to and from the activity counts.

What is “deeper involvement”?

Deeper Involvement refers to a relationship with an entity for which you are requesting approval to work that extends beyond the work itself. Examples include, but are not limited to, extensive and long-term consulting with a for-profit entity, ownership of a for-profit entity, a line-management position with a for-profit entity or other involvement in its day-to-day operations, a key continuing role in the scientific or technical effort of a for-profit entity, and providing assistance to a for-profit entity in the development or commercialization of an idea involving your expertise or technology that you have developed. Outside work with deeper involvement usually requires more extensive review and the implementation of a plan to manage resulting conflict.

What if my proposed outside work will amount to more outside work days than I am eligible for under the policy?

Generally, days in excess of those outlined under the outside work policy will not be approved. Instead, a leave of absence or other arrangement would need to be made by you and your school or college.

What is usually not allowed?

Examples of situations that would generally not be allowed as outside work (assuming you are a 100% UW FTE employee) include outside work for more than 52 days over a one-year period without taking leave, teaching or conducting research at another institution, and performing work if your current visa status does not include work for an employer other than the UW.

What is the difference between requesting approval for outside work and disclosing paid consulting through the Financial Interest Disclosure System (FIDS)?

Your FIDS disclosure is required to initiate the process for assuring that your research or technology transfer activities are not in conflict with the financial interest resulting from your consulting. Your Form 1460 will be reviewed for conflicts with other UW policies and other types of conflicts, such as academic conflicts.

Do I need to request approval for outside work if I am on a nonimmigrant visa?

Outside work for compensation may not be allowed for persons on nonimmigrant visas. Please consult with the International Scholars Operations.

When

When do I need to request approval?

The policy stipulates that approval is required before the outside work begins. Please make every effort to request approval as soon as you know you will be performing the work. This will allow time for your request to be reviewed and approved and for a management plan to be established, if necessary.

Do I need to request approval for outside work that is already underway or has already been completed?

Yes. You should complete Form 1460 and submit it for review and approval by your department chair and dean or chancellor. While the request cannot fulfill the requirement for “prior” approval, the Office of Research will keep a record on file that you submitted a Form 1460. In the future, be certain to request approval in advance. This provides protection for you of potential violations of the Washington State Public Ethics Law.

How long will the approval process take?

Requests that are complete and do not involve any conflicts may be approved in the Office of Research in as little as three business days. Of course, your Form 1460 must first be reviewed and approved by your school or college. Those requiring more information or the development of a management plan, or that constitute deeper involvement, will take longer depending upon the situation.

How

How do I calculate the amount of time (days) to request if I am not exactly certain how much time I will be working?

If you do not know the exact number of days you will be engaged in outside work, provide an outside estimate – the greatest number of days you may be engaged. The approval will be based on the time estimate you provide.

How will I know if my request has been approved?

Notifications will be sent by email to you and to your school or college as soon as your request is approved. You may always contact the Office of Research (work1460@uw.edu) to inquire about the status of your request.

I consult by the hour. How do I calculate the number of days?

Eight hours constitutes one day. Include travel time. If you spend more than 8 hours in a single 24-hour period, count it as 1 day. As an example: If you spend 1 hour per week on your cell phone for 8 weeks, plus a single 4-hour visit to the company with 3 hours of travel time each way, the total would be 2 days.