Conflicts of Commitment (CoC)
The term “conflict of commitment” relates to an employee’s distribution of effort between University Duties or Institutional Responsibilities (primary and secondary), and external professional activities.
External Activities
- SHRA employees: the review process is administered by Human Resources through the Secondary Employment Policy.
- EHRA Faculty and non Faculty, including Postdoctoral Fellows: the review process is administered through the EPAP module in the AIR system.
All EHRA Faculty and EHRA non-Faculty employees of the University are expected to devote their primary professional loyalty, time and energy to their Institutional Responsibilities. Institutional Responsibilities are comprised of primary duties and secondary duties.
EHRA Faculty and EHRA non-Faculty employees of the University may participate in activities for compensation outside of their Institutional Duties, provide such participation is consistent with the University of North Carolina Board of Governors’ Conflict of Interest and Commitment and Regulations on External Professional Activities for Pay by Faculty and EHRA Non-Faculty Employees.
As stated in the Conflict of Commitment Policy, in addition to school level review, some EPAP requests are subject to further review by the Office of Technology Commercialization and the Provost Office or Office Human Resources, as applicable.
While generally conflict of interest review occurs after the EPAP activity has been approved, in situations where the Offices have concerns that the external activity creates a high level of conflict, a COI review can be requested prior to final determination of the EPAP request.
Primary Duties
- Assigned teaching
- Scholarship
- Research
- Institutional service requirements
- Administrative duties
- Other assigned employment duties
Secondary Duties
Secondary duties may include professional affiliations and activities traditionally undertaken by University employees outside of the immediate University employment context. Secondary duties may or may not entail the receipt of Honoraria, remuneration (see additional regulations, UNC System Office Policy Manual, 300.2.2.2 [R]), or the reimbursement of expenses. A list of these duties would include:
- Membership in and service to professional associations and learned societies;
- Membership on professional review or advisory panels;
- Presentation of lectures, papers, concerts or exhibits;
- Participation in seminars and conferences;
- Reviewing or editing scholarly publications and books without receipt of compensation;
- Service to accreditation bodies.
Time Parameters
University policy does not provide that an EHRA faculty or non-faculty employee is entitled to engage in any EPAP for any specific or set percentage of time. EPAP activities for an EHRA faculty or non-faculty employees are limited to no more than twenty percent (20%) of the Covered Individual’s time at 1.0 FTE, consistent with UNC System Office regulations. An employee’s supervisor always has the discretion to determine whether a proposed external activity is appropriate in scope or duration or constitutes excessive time away from Institutional Responsibilities, regardless of the amount of time requested. Further guidance is in the Policy.
Employees are required to receive approval in advance for any External Professional Activities for Pay (EPAP).
External Contracts
EPAP activities, or any contracts signed by a Covered Individual in support of the activity, must be in compliance with University policies, such as the assignment of Intellectual Property or disclosure of entities involved in the activity. Individuals should consult the Office of Technology Commercialization and other applicable University offices for further guidance about specific clauses; individuals should be wary of signing contracts which limits their ability to share information with the University as their primary employer.