Health Sciences faculty asked to review proposed BOG governance rule 1.4

External consulting, entrepreneurial work could be affected

Thursday, November 15, 2018

All Health Sciences faculty members are requested to review a proposed Board of Governors Rule currently in a 30-day comment period: WVU Governance Rule 1.4 on Ethics, Conflict of Interest, and Outside Consulting.

As this is a rule that impacts all faculty, especially those who engage in outside consulting or entrepreneurial activities, all are encouraged to review the proposed rule before the comment period elapses. While this is a “public comment” period and is therefore open to everyone, the intent is to seek constructive comments from faculty during this period.

The review period for the proposed rule closes on December 12.  

Please visit the website for proposed rules: https://policies.wvu.edu.

Once on the website, there is a link that will take users to a summary of the proposed rule, which is an amended version of BoG Policy 17.  

The Ethics Rule is mostly inherited from state code and covers issues such as acceptance of gifts, use of university resources, interests in public contracts, endorsements, and dual government compensation.

The Conflict of Interest Rule establishes a Conflict of Interest Committee to deal with real and perceived conflicts of interest/commitment and sets forth reporting requirements for University Officials. As before, all research investigators must submit a Conflict of Interests in Research Disclosure at least annually. 

The Outside Consulting Rule includes expanded requirements for reporting consulting engagements, including a new requirement to submit an annual disclosure of consulting activities (see section 7.4) and a clarification that full-time faculty cannot engage in regular part-time employment outside of the university (see section 7.2.3.1).  Faculty on a 12-month appointment (i.e., leave eligible), are expected to take annual leave when performing consulting activities during normal working hours (see section 7.2.1).

For your reference, drafts of the Outside Consulting Approval Form and Consulting Arrangement Annual Disclosure Form were presented at this Monday’s Faculty Senate meeting.

If you would like to comment on the proposed Rule, you can do so by going to the Rule and clicking the “comment on this policy” link. This is the only official mechanism for commenting on the Rule.

Faculty are encouraged to review the proposed Rule especially with your own circumstances in mind, making sure that it adequately covers your situation.  If it is unclear how it may apply to you, then you could enter a corresponding comment.

The comment form asks you to enter your name and email, but this is only so the University can follow up with you in the event that your comment contains a question or is unclear.  Once the comment period expires, the University will post all comments received or their summaries (with names of the submitter removed) on the designated policy website for 10 calendar days before final Board of Governors action is taken.  

Please know that your comments are given serious consideration. Each one will be reviewed by the Board, and the Rule may be revised in response to the comments. If you make a comment, your name will not appear in the posted comments and will not be provided to the Board of Governors. Comments that are too specific to an individual will be summarized.