The External Professional Activities (EPA) Policy went into effect on April 27, 2022. Take a few short steps now to get ready.

  1. Review Prior Approval Guidance to become familiar with which activities require prior approval:
    • For prior approval (PA) activities already active: You do not need to submit a Prior Approval Request for activities that have been ongoing since before the policy went into effect. When requested to update your full disclosure, make sure the activities are fully disclosed.
    • For PA activities already planned and starting after the policy effective date: A PA Request is not required, however discuss the anticipated activity with your School/Dept. Designated Reviewer prior to the activity starting, follow any instructions s/he provides and update your full disclosure within 30 days of the initiation of the activity.
    • For PA activities in early development: A PA Request is required prior to initiating the activity to enable review by the Designated Reviewer. This may include a requirement to provide a copy of the proposed contract.
  2. Gather relevant contracts or other documentation that you may need to provide as part of your disclosure:
    • Contact the organization if you are unable to locate the agreement, or do not have a written agreement, to obtain a copy or begin the process of establishing a written contract.
    • If needed, provide a translated version for non-English contracts, either by an independent third-party or using software.
    • The University does not formally approve your personal agreements/contracts; however, they may be reviewed to advise you on best practices and alignment with institutional or regulatory requirements. At a minimum you can anticipate providing contracts for:
      • Any foreign appointments and/or employment with a foreign entity including agreements for activities or resources provided by or on behalf of a foreign entity.
      • For Physicians and Health Professionals: personal contracts with medical/healthcare entities.
  3. No immediate impact on your full External Professional Activities Disclosure (formerly called Financial Disclosure Statement or FDS):
    • There is no need to immediately update your full EPA Disclosure unless you have started a new activity within the last 30 days or it is time for your annual update.
    • The COI Office will continue to notify you to update your disclosure two weeks prior to its expiring.
    • All of your existing disclosure data remains in the disclosure system and will pull into the updated EPA Disclosure automatically when you go to update your disclosure.
    • There are some new questions on the disclosure so you will need to answer those before you will be able to submit, even if there have been no changes to your external activities.