Outside Interests and Employment

Outside professional activities and interests are an accepted part of academic life. They make faculty better scholars and teachers, and thereby better equipped to serve the University. Nonetheless, the opportunities available to faculty and other officers to conduct research, engage in consulting, practice their professions, and turn their discoveries and ideas into commercial ventures create the potential for conflict between their outside interests and commitments and their responsibilities to the University. Outside professional interests and employment, whether gainful or not, must not interfere with an officer’s teaching, scholarly research, and other departmental and University duties. Even the appearance of a conflict can be injurious to both the individual officer and the University.

The primary professional obligations of full-time faculty are to the University. They consequently may not participate in any outside activities, for or without compensation, that will absorb an undue amount of their time and thereby interfere with the performance of their University duties. Outside employment, consulting, and other interests may not require an average commitment of more than 20 percent of their time during the period in which a faculty member is expected to provide services to the University, except in the case of participants in faculty practice plans at the Irving Medical Center whose outside activities are determined by those plans.

Depending upon the nature of the outside activity, a conflict of interest or a conflict of commitment may exist even when a faculty member observes the time limit prescribed by the University’s policies, or engages in the outside activity during vacations or the summer months in the case of those serving in schools on eight- or nine-month academic calendars. This has become increasingly true in recent years as new information technologies have greatly expanded the opportunities for faculty and other members of the University community to create and disseminate their work to new audiences in new ways. Faculty may not engage in outside activities that directly compete with the mission and interests of the University or are in conflict with their University responsibilities, regardless of the time they require. Those activities may not adversely affect their independence or compromise the integrity of the University.

Full-time faculty may not create courses, substantial parts of courses, or courseware for other educational institutions or a commercial enterprise, nor may they accept teaching assignments outside of Columbia, unless specifically authorized in advance by the Provost on the recommendation of the appropriate dean or executive vice president. This policy applies equally to courses taught in person, online, or by some other method of electronic transmittal. It does not prevent faculty from giving guest lectures at another institution or engaging in similar activities, but faculty should be sensitive to the fact that the distinction between occasional lectures, which are a normal part of academic life, and a teaching assignment, which requires prior approval, is not always clear cut. When there is any question as to whether an outside engagement falls within the range of allowable activities, a faculty member should first consult with the appropriate dean or executive vice president or with the Vice Provost for Faculty Affairs. Prior provostial approval is also required to hold full-time positions outside of the University. Officers who wish to be the principal investigator on an externally funded award that is administered by another institution need the prior authorization of the Executive Vice President for Research.

Outside activities must not conflict with the University’s patent and copyright policies. Intellectual property rights in the patentable inventions and discoveries, and any associated technology, of its officers generally vest in the University if they result primarily from the use of its facilities or from work while engaged in its service. The University claims copyright ownership to works of authorship by its faculty and officers of research in more limited circumstances, as defined by its Copyright Policy, primarily when the works are created with substantial use of University resources or are commissioned for use by the University.

Faculty and officers of research may not engage in consulting activity involving any technology in which the University has rights, or involving University work that seems likely to give rise to such technology, on terms that vest control of it in a commercial enterprise, without the prior approval of Columbia Technology Ventures. Faculty and officers may not divert University materials, supplies, facilities, or personnel to support outside consulting assignments. Finally, they should avoid entering into consulting agreements that could give rise to overlapping intellectual property claims by both the University and the sponsoring entity.

The responsibility for recognizing and avoiding conflicts of interest rests primarily with the individual. To aid and protect all concerned, the University has put in place a number of policies and procedures. Many of these were incorporated into the "Statement of University Policy on Conflicts of Interest,” which was issued in 1987. In 1986, the University adopted a separate statement on the potential commercial and industrial applications of scientific and technological research. This statement provides guidelines for avoiding conflicts between the commercial opportunities arising from such research and an officer’s University responsibilities. The University’s Policy on Financial Conflicts of Interest and Research promotes the objectivity of Columbia research in the context of researchers’ outside activities and financial interests. The companion Policy on Institutional Conflicts of Interest in Research similarly does so with respect to Columbia’s own financial interests and those of its officials. The Irving Medical Center also has policies that address conflicts of interest in clinical care and medical education, as described online in the “Conflict of Interest Policy on Education, Clinical Care, and Administration for Faculty and Researchers at Columbia University Irving Medical Center.”

To monitor for conflicts of interest and provide guidance regarding specific activities, the University requires all faculty to file an annual disclosure statement of their outside financial interests and activities, including all appointments and affiliations with institutions of higher education, academic medical centers, and research institutes, whether paid, unpaid or honorary. Faculty also must disclose all roles on prime awards to institutions other than Columbia, such as co-principal investigator or co-investigator (this does not apply to roles on incoming subawards and subcontracts from another institution to Columbia). All full-time officers of instruction, including tenured and tenure-track faculty, professors of professional practice, lecturers, lecturers in a particular discipline, and lecturers at the Columbia University Irving Medical Center whose only responsibility is to teach, as well as all principal investigators and other individuals who conduct research, must file the disclosures.

Broad disclosures of appointments and affiliations is required because such positions may constitute or appear to constitute competition with the University, affect an officer’s ability to carry out their duties and obligations to the University; create the risk of loss of the University’s intellectual property; and dilute the University’s academic reputation and leadership, especially when the faculty are listed as affiliates in publications or presentations. Individuals must also disclose all financial interests related to their institutional responsibilities, and not limit disclosure of financial interests to those related to research in order to help protect against reputational risk to the individuals and to the University arising from conflicts of commitment and conflicts of interest. Faculty must also confirm that their participation in outside activities complies with the University’s conflict of commitment policies with respect to time spent (up to roughly 20 percent time/one day a week) during the academic year. Subject to any summer commitments to sponsored projects or other University activities, faculty on nine-month appointments may also spend time during the summers participating in outside activities.

Relevant deans or vice presidents, or their designees, review disclosure forms completed by officers of instruction and research for potential conflict of commitment with University, school, and departmental obligations. The Office of Research Compliance and Training initially reviews these disclosure forms for potential conflicts of interest related to Columbia research. Forms that disclose significant financial interests, as defined in the Research Conflict of Interest Policy, are reviewed by the Financial Conflict of Interest Committee, which is appointed by the Executive Vice President for Research and consists of officers of instruction and research, as well as non-voting senior officers of administration. Officers may appeal committee decisions to the Executive Vice President for Research whose determination is final. If the Office of Research Compliance and Training identifies a potential conflict of interest that do not involve research, it refers the case to the appropriate dean or executive vice president or to the Provost whose determination is final.

At a minimum, prior approval by the relevant chair, dean, director or executive vice president is required for any titled and compensated appointments and affiliations with institutions of higher education, academic medical centers and research institutes. Disclosures relating to companies are generally covered by the Policy on Financial Interests and Research disclosure requirements, which include both compensated roles and special company relationships with the potential for personal financial gain. Any particular school may impose more stringent prior approval requirements, but may not impose less stringent requirements.

Concurrent appointments, such as with companies, research institutes, academic medical centers, or nonprofit or governmental entities, that exceed the time allowed under the University’s leave of absence policies may also pose a risk of conflict of commitment because individuals with such appointments may be unable to fulfill teaching, research, and service obligations to the University, and may prioritize the other appointment over the University. On the other hand, in some fields, access to state-of-the-art technology and data may occur only through such interactions with companies and other entities. Work in non-academic environments may afford scholarly insights and networks of value to the individual and the relevant academic units at the University. In addition, public service has broader societal benefit as well as potential benefit to the department, school, institute, or center.

Requests for such concurrent appointments may be approved only where they benefit the University. The initial term is limited to one year and requires the approval of the department chair, director, dean or executive vice president. The Provost, upon the recommendation of the chair, director, dean or executive vice president, may grant a one-year extension provided that the concurrent appointment continues to benefit the University. Concurrent appointments are generally limited to two years. Any further extension is allowable only on the recommendation of a faculty committee appointed by the dean. The committee must consist of at least two members of the relevant department or equivalent unit and at least two members from outside that unit, and may include faculty from outside the school.  The committee must assess the full impact of the concurrent appointment on the research, teaching and service of the faculty member seeking the extension, and recommend whether a further extension would continue to benefit the University. The committee must provide a report of its conclusions to the relevant dean, director or Executive Vice President, who will provide the report and the school’s recommendation to the Provost. The Provost will make the final decision on any further extensions. Such extensions are limited to two years after which a new review would be required for an additional extension.

Officers of research are subject to the University’s conflict of interest policies.  An officer of research normally may not undertake any outside employment except after consultation with his or her department head or supervisor.  In the event that the department head or supervisor is conflicted as to the outside employment or activity, the approval must be at the school level.