Faculty, Librarians and Academic Staff: Paper forms are no longer being accepted. Form 1460s and SoM Supplements must now be submitted online.
The application and instructions for submission can be accessed at https://apps.som.washington.edu/OutsideWork. A detailed help guide for the creation of requests can be accessed here.
First-time users of the online system are encouraged to watch a video tutorial of how to complete a form 1460. The video is found here.
Questions regarding the SoM outside work process should be directed to the School of Medicine Dean’s Office Business Unit at SoMOutsideWork@uw.edu.
Subject to certain limited exceptions, all employed faculty, librarians and other academic personnel within the School of Medicine (SoM) who desire to engage in outside work for compensation are required to obtain prior written approval from the University using the Request for Approval of Outside Professional Work for Compensation (Form 1460), which is the form used by all UW faculty, librarians and other academic personnel.
The UW Outside Professional Work Policy (Executive Order 57) requirements, guidance and form can be viewed on the Office of Research webpage.
In addition to completing a Request for Approval, the UW Medicine Policy for Faculty on Potential Financial Conflicts of Interest with Commercial or Nonprofit Entities requires that SoM employed faculty disclose additional information on a supplemental form to the Request for Approval. The SoM Supplement requests information regarding:
- Amount of compensation:
- - Estimated or actual
- - Proposed and waived
- Equity interests
- Travel, lodging or other in-kind benefits
The requirement to file exists regardless of whether the individual chooses to receive the compensation, direct it somewhere else, or waive the compensation.
After completing the online 1460 Request for Approval and the SoM Supplement , the request will automatically route as follows for review of the activities:
- Division Reviewer then Division Head (if required by Department’s policy).
- Department Reviewer then Department Chair (required) for review of the activities. After evaluating the forms, the department chair makes a recommendation regarding whether the outside work should be approved.
- Dean’s Office Reviewer then Director of Regulatory Guidance in the Business Unit of the Dean’s Office for review and a determination of whether the request should be approved by the SoM. Review of the SoM Supplement ends here in the Dean’s Office.
- After the Dean’s Office has reviewed and approved the Request for Approval, it will be forwarded to the Office of Research. The applicant, department, and SoM will be notified by the Office of Research once a final determination is made.
Certain kinds of university and community service activities do not require prior written approval even though compensation in the form of an honorarium is paid. These limited exceptions are more fully described in the UW Outside Professional Work Policy (Executive Order 57) but include activities that are complementary to University responsibilities, such as participation in the work of nonprofit professional associations and societies.
Many faculty and staff who do outside work generously choose to direct this compensation back to the University in the form of a gift. You may find information about gifts that result from outside work here.
FREQUENTLY ASKED QUESTIONS
Where can I find the outside work request forms for School of Medicine faculty?
The online application can be found here. A UW NetID is required.
Where can I find the status of my application?
Faculty can see their own requests and the status of their applications on the online application platform (here). Other departmental persons may also be able to see this information for faculty in their divisions or departments based on their role and permissions.
Can I submit one Request for Approval for an ongoing and multi-year consulting relationship I have with an organization?
No. You may submit one form for each academic year (July 1 to June 30) and provide the number of total days for the academic year, as well as total compensation expected for the academic year on the SoM Supplement.
How long will it take to review my Request for Approval? How early should I submit the form before my consulting activity begins?
You should submit your form as soon as possible because your request needs to be reviewed by both the SoM Dean’s Office and the UW Office of Research. Review may take as long as 8 weeks, depending on the complexity of the form and the time of year.
Should I submit a Request for Approval for a consulting activity that I have already performed and been paid for?
Yes. Ideally the form should be submitted for approval PRIOR to beginning the work, but we understand this does not always happen. The form should be completed as close in time to the activity as possible.
Who is required to submit Requests for Approval? Are all UW faculty members required to do this?
The UW Policy for Outside Professional Work for Compensation applies to “members of the faculty, librarians, and other academic personnel” regardless of the funding source supporting their position.
Members of the UW faculty are defined in the Faculty Code in the UW Policy Directory:
Section 21-31 Membership in the Faculty
The University faculty consists of: President, Provost, professors, associate professors, assistant professors, principal lecturers, senior lecturers and senior artists in residence, professors of practice, lecturers and artists in residence, instructors, teaching and research associates whether serving under visiting, acting, research, clinical, or affiliate appointment, whether serving part-time or full-time, and whether serving in an active or emeritus capacity. The faculty, beginning with the professor, are listed in order for purposes of determining voting eligibility based on superior rank.
Section 13-31, April 16, 1956; S-A 29, June 8, 1964, S-A 32, May 8, 1967, S-A 78, December 14, 1988: all with Presidential approval; RC, February 1, 2008; S-A 124, July 5, 2011; S-A 133, June 11, 2014: both with Presidential approval; RC, September 30, 2014.
Is there a limit as to how much time I can spend performing outside work?
Yes: 13 calendar days per academic quarter, which, with prior approval, may be averaged across quarters of an academic year provided that no outside consulting work will be approved that impairs the employee’s ability to carry out regularly scheduled teaching or other work assignments or to complete the terms of grants and contracts.
Is there a limit as to how much compensation I can receive for outside consulting activities?
Payment should be commensurate with the amount of time and effort spent on the activity and should be fair market value. The SoM has an internal review process for situations in which there is an initial determination that the fair market value standard is not met.
Do I need to submit a Request for Approval if a company pays for my personal travel expenses to participate in an outside activity?
Yes, the payment of travel expenses is considered remuneration and must be reported on the SoM Supplement.
What happens if my Request for Approval is not approved?
A 1460 is rarely “not approved.” The Director of Regulatory Guidance will work with the faculty member, the Department and the Office of Research to amend the request so that the activities will work within the confines of the University policies and regulations.
I want to donate the compensation offered by the company for outside work to the UW, how can I do that?
There are two ways the compensation can be donated, and you should consult your personal financial advisor to ensure you understand any personal tax consequence under either option:
- You personally donate the compensation as a gift, or
- You waive the compensation and the company decides to make a donation to the University in recognition of your work.
For details on these two options and how the University of Washington processes gifts that result from outside work, please review these guidelines and procedures.
TYPES OF OUTSIDE WORK
Are Requests for Approval required for organizing or presenting CME activities?
If you are participating in continuing education activities not under the aegis of the University of Washington, prior approval for such activities must be sought in accordance with the Outside Work Policy procedure.
If my outside consulting activities involve University of Washington patients, can I receive compensation?
No. Any work involving UW patients, such as medico-legal consulting, should be billed through the appropriate practice plan. More information, including FAQs regarding expert witness work, can be found here.
Can I do clinical work as outside work?
In general, full-time faculty (50% or greater total FTE) who are members of UWP or CUMG are not permitted to engage in Independent Clinical Practice, as defined by the Sites of Practice Policy. Members of UWP or CUMG who are part-time (less than 50% total FTE) are permitted to engage in Independent Clinical Practice as approved by the member’s department chair and the Outside Work process.
More information can be found in the Committee on Medical Practice Initiatives and Sites of Practice Policy on Approval for Clinical Practice.
Can I teach a course at another institution? What if it is for undergraduate students? What about online courses?
Faculty may not duplicate their efforts outside of the UW. This includes teaching, research and clinical work (see above regarding clinical work). Full-time faculty may not teach for-credit classes at other institutions of higher education, even if they do not currently teach at the UW. This includes undergraduate courses and online courses. Faculty who wish to teach credit courses must reduce their appointment before receiving approval for the outside work.
See also Office of Research Outside Work FAQs on general UW requirements.
Why does the UW Medicine Policy for Faculty on Potential Financial Conflicts of Interest with Commercial or Nonprofit Entities prohibit SoM faculty from participating on a commercial entity’s speakers bureau?
Whenever SoM faculty are present at programs designed solely or predominantly for company promotional, sales or marketing purposes, the faculty participation, even though compliant with the fair market value standard, can create a real and inappropriate conflict of interest situation. In addition, the policies of several peer medical schools across the country contain similar prohibitions.
Does the prohibition on participating on a speakers bureau apply even if the speech given is about the science relating to a disease or condition as opposed to one that directly advocates for the company’s product?
Yes, the conflict of interest starts with the presence of a faculty member’s name in a company’s list of individuals maintained by the company (“Speakers Bureau”). The implication to the public if a faculty member’s name appears on that list is that the faculty member directly or indirectly “works for the company’’ or/and that faculty member’s role is to advance the interests of the company.
Does the prohibition on participating on a speakers bureau apply if the speaker retains control of the content of the presentation and/or any slides that may accompany the presentation?
Yes, regardless of who is responsible for the content of the presentation, it is in fact the willingness to participate in a Speakers Bureau – to be named on a list maintained by a company that leads to the perception of promoting a company’s product or service.
Does the prohibition apply if the activity is not called a “speakers bureau’’?
Yes, regardless of the label, the prohibition applies to participation as a speaker, panelist, presenter, or commentator in any activity or event funded, directly or indirectly, by a commercial entity where the event is, or may be perceived to be, a promotional event for the sponsoring organization and/or its products of services.
I have been invited to give a talk at a symposium that is being sponsored by a drug or device company. The symposium has received the funding and I was asked by the symposium steering committee to participate and they will pay my travel, accommodations and an honorarium for my participation. I am not receiving money from the company. Is this allowed?
Under the COI policy as long as the symposium meets the standards for a CME activity (industry does not pick the speakers, control the content, etc.), participation in the symposium is permitted. However, you must still comply with and seek approval pursuant to the University’s outside work policy.
I have been invited to speak at Grand Rounds by a peer institution where the invited speakers are paid directly by a pharmaceutical company for speaking, yet the company has no influence in terms of content. Is this allowed?
So long as the Grand Rounds meets the standards for a CME activity, and neither is, nor is perceived to be, a promotional event for a company and/or its products or services, compensation directly by the company is not prohibited. However, please be aware that such direct payment is not considered best practice, may need to be disclosed under the University rules related to conflict of interest in research (GIM 10), and will be publicly disclosed by the company (pharmaceutical or device manufacturer) under the Open Payments Act. See CMS Website for Physician Payments Sunshine Act.
If I am asked my opinion about a drug or device that I use in my clinical practice during a panel discussion or at a conference am I allowed to give my opinion?
You are free to give your opinion on the effectiveness of any product or device. You may not do it as part of any program put on by the manufacturer for the intention of promotion of the product or device.
My work has led to the invention or further improvement of a product or device. Am I allowed to give my opinion of the effectiveness of that product or device?
In the context of your University employment, you may give your opinion if asked, for example by a UW Medicine purchasing committee, but you must disclose your financial interest in the product and recuse yourself from any purchasing decision. There may also be limited circumstances where you may appear on behalf of industry as indicated in the policy, including in situations where you have a financial interest in the product and are doing approved outside work involving that product.
Does the COI policy apply to unpaid clinical faculty members who teach residents in their practice at a WWAMI site?
The existing policy applies specifically to faculty employed by the University and its close affiliates. All faculty not otherwise covered are currently encouraged to follow the intent of the policy and its guidelines. However, the prohibitions on speakers bureau participation and commercial product endorsement apply to all (paid and unpaid