External Professional Activities: Procedure and Guidance

Employees covered by REG 01.25.01 – Conflicts of Interest and Conflicts of Commitment must disclose and obtain prior approval for any External Professional Activity (EPA). This guidance is intended to help you determine which EPAs you’re required to disclose. 

Disclosing these activities promptly allows NC State to address concerns about potential conflicts of commitment and provide covered employees the tools and information they need to protect their work, meet federal research security requirements, and minimize risks. This proactive approach helps identify any significant changes to activities or agreements required before EPAs commence.

What is an External Professional Activity?

External Professional Activity is defined as any paid or unpaid activity that:

1. Is based on the professional knowledge, experience or abilities for which NC State employs the Covered Individual,
2. Performed for an entity other than NC State and,
3. Is not included in the Covered Individual’s University Employment Responsibilities unless the Covered Individual:
   • Has accepted a formal Academic Appointment, Professional Appointment, or Institutional Appointment, paid or unpaid, with an entity other than NC State, or
   • Is participating in a Foreign Talent Recruitment Program, or
   • Is receiving direct compensation for the activity from any entity other than NC State, or
   • Has travel sponsored or reimbursed by an entity other than NC State, unless the travel is reimbursed or sponsored by a U.S. federal, state, or local government agency, a U.S. institution of higher education, a U.S. academic teaching hospital, a U.S. medical center, or a research institute that is affiliated with a U.S. institution of higher education.

Still unsure? Please refer to the EPA Disclosure Decision Chart.

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Who must submit an EPA disclosure form?

Covered Individuals include:

• Faculty employees (Classified as EHRA Faculty)
  • Inclusive of all faculty, including Extension, Teaching, and Research
• Exempt Professional Staff (EPS) employees (previously called EHRA Non-Faculty)
• Senior Administrative and Academic Officers (SAAO)
• Any individual, regardless of employment type or status, serving as Senior/Key Personnel on a sponsored research project
• Anyone supported by a particular sponsored research project, as required by specific federal award terms*

*Individuals in this category will be notified of their inclusion and shall be subject to this regulation only for the period of time they participate in the applicable project.

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When should I submit or update my EPA disclosure form?

Per NC State REG 01.25.01, Covered Individuals are required to obtain approval from their Unit Head prior to engaging in an External Professional Activity and annually thereafter.

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Do I need to renew my EPA Disclosure for ongoing activities at the beginning of each Fiscal year?

Per NC State REG 01.25.01, all EPA approvals expire at the end of the fiscal year, June 30, regardless of when your activity ends. If your EPA continues beyond June 30, you must file an additional request for the next year. This year’s renewal period will begin on May 1 in the Research Enterprise Data (RED) system, after which approvals are in effect for the next full fiscal year.

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How do I file an EPA disclosure form?

New and ongoing External Professional Activities should be disclosed to NC State University through the Research Enterprise Data (RED) system and to research sponsors. For step-by-step instructions on how to file or edit an EPA disclosure in RED, refer to this guide.

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If I intend to engage in an EPA, do I need to update my Financial Interest disclosure?

Yes, if the EPA is paid; once your EPA has been approved by your Unit Head, you should update your Financial Interest disclosure accordingly within 30 days of commencing the EPA. For advice on COI policies and procedures, please email coi-support@ncsu.edu or call 919.513.8141.

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Can I have a TSA with a firm with which I am engaged in an EPA?

Technically, no. The rules governing a Testing and Services Agreement (TSA) clearly state the TSA is appropriate for work performed and where:

• “such efforts will not have any research component.”
• individuals involved “shall not work as a consultant for the same client during the term of any services agreement or for the purpose [of] creating the client’s protocol or interpreting or analyzing the data delivered without an approved conflict of interest management plan. Mitigation of such situations shall be handled under the university’s conflict of interest policy and with the use of an appropriate management plan developed by the individual and approved by the department head and dean of the college.”

Please see the Office of General Counsel’s Consulting FAQ for more information.

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Can I consult with a company for which my lab is performing services under a TSA?

Generally not. TSAs are designed for use in cases where there is no research component. If a university employee (whether acting as a consultant or on behalf of the university) provides an analysis of results or interpretation of data, the project becomes research and should be contracted with the university pursuant to a sponsored research agreement. University guidelines for TSAs prohibit consulting by individuals who also supervise staff/students performing the tests, determine use rates, or administer the contract TSA on behalf of the university (See Guidelines for Testing Service Agreement (TSA) Activities). Furthermore, such consulting may be in violation of state law, which prohibits employees from benefiting from public contracts (See N.C.G.S. 14-234 (a)(1)).

In general, it does not appear possible to “firewall” your EPAP engagement with a firm that is conducting business with a service center in which you are a principal (director, employee, participant, student, or other affiliation). Cases should be reviewed by the department head and dean on an individual basis.

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