When to Do What
The OAP uses the calendar year (CY) as the basis for its annual cycle to align with the tax year. It uses the first quarter of the following year as its Annual Finalization Period. For example, Jan. 1 through March 31 of 2014 was the Annual Finalization Period for the 2013 calendar year. Thus, during this time period, faculty and staff disclosed activities and resolved actual or potential conflicts of interest and/or conflicts of commitment that took place the previous year, CY2013. They will also finalize these activities and declare them ended through a certification process. At the same time and through the rest of CY2014, they will be doing the same for activities originating in CY2014.
Activities During Fall 2014
In the past, faculty and staff have filed Requests for Outside Employment at the start of the fall semester and any time thereafter during the academic year (AY) with each new outside employment. These requests expired at the end of the academic year and had to be renewed for the subsequent AY if they extended into the next AY. Under the new policy (HOP 5-2011), the Calendar Year (CY) is the basis for filing Requests for Prior Approval. Faculty and staff will file those requests at the start of the CY for any new or continuing outside activity or within a CY whenever it occurs. If the activity extends beyond the end of the CY, then a new Request needs to be filed to cover that extension. This is easily accomplished using the Duplicate feature in the Request for Prior Approval process. Supervisors will review and approve these Requests as appropriate.
Each Request for Prior Approval created in UT System’s OAP generates a Disclosure which is finalized by the faculty member or staff any time after the disclosure is created, the activity is approved, once the outside activity is completed, or during the Annual Finalization Period, i.e., the first quarter of the subsequent CY. If the activity continues past a given calendar year then not only can the Request for Prior Approval be extended easily but the Disclosure may be also.
With the start of the Fall 2014 semester, faculty and staff may file Requests for Prior Approvals for outside activities that start during the fall semester as well as those that begin after Jan. 1 (the beginning of CY2015). These requests are good for one year only, so Requests for Prior Approval submitted at the start of the Fall 2014 semester that extend into the next calendar year will need to be renewed sometime on or after Jan. 1 so the activity is ultimately disclosed during the Annual Finalization Period.
Activities During CY 2015
During the first quarter of CY2015 (Jan. 1 through March 31, 2015), Disclosures for outside employment and other activities that took place in CY2014 must be finalized. Once faculty and staff have checked over these disclosures and confirmed they are accurate and complete, they finalize the disclosures (in effect, they electronically sign the disclosures) then certify them, all within the “Make A Disclosure” portal. Once certified the disclosures may not be edited or deactivated.
Requests for Prior Approval can be made anytime during the calendar year, but these Requests must be prepared and submitted before the outside employment or activity actually begins so they may be reviewed and approved by the supervisor. Many of these Requests may have been submitted at the start of the fall 2014 semester as noted above and carried forward. When possible, faculty and staff should prepare these requests at the start of CY2015 to stay in the calendar year cycle. However, if the outside employment or activity is scheduled to start during the fall 2014 semester, then “Requests for Prior Approval” must be submitted before that employment or activity begins. Supervisors will review and approve these Requests as they are submitted.
Outside employment or activity that will continue beyond CY2015 can easily be accommodated within the “Request for Prior Approval” portal using the Duplicate feature. All of the information submitted will be duplicated except the start and end dates, and that information must be updated.
Disclosures may also be made anytime during CY2015. Any changes in the Disclosure that take place before the Annual Finalization Period begins can be made during that period. Disclosures may also be carried forward for outside activities that extend beyond the calendar year.