PSOM Extramural

The annual extramural reporting tool is now seamlessly integrated with the research reporting tool known as Research, Interests, and Activities (RIA). You will receive an email prompting you to complete your annual extramural disclosure for the previous calendar year. As in years past, you will be asked to report on various items that may require you to reference documentation associated with your extramural activity.

Live support is available through Zoom from 12PM to 1PM on Tuesdays and Thursdays starting July 2nd.

A live training session will be held on Monday, July 8, at 12PM for one hour. This will be recorded and posted here for anyone unable to attend.
Zoom Training Session

FAQs

Who needs to submit an Extramural Disclosure?

The University of Pennsylvania and Penn Medicine require that members of the faculty, academic support staff, Penn Medicine Clinicians, Penn Primary Care, clinical faculty, and adjunct faculty who are compensated and/or participate in research comply with all policies and procedures and federal regulations relating to extramural consultative and business activities and conflict of interest. Accordingly, you are required to disclose all extramural activities during your employment at the University of Pennsylvania during calendar year 2023 (January 1, 2023 through December 31, 2023) through the web-based reporting system by July 29, 2024.

I have no outside activities or interests. Do I still need to complete an Extramural Disclosure?

Please note that you are required to complete the disclosure even if you had no extramural activities in the calendar year 2023. Simply answer “no” as appropriate.

Where do I find the Extramural Reporting Form?

The annual extramural reporting tool is now seamlessly integrated with the research reporting tool that many of you already use, known as Research, Interests, and Activities (RIA). You can access this tool using the following link and you will be prompted to sign in using your PennKey and password: https://apps.research.upenn.edu/login

What is the reporting period?

The reporting period is a full calendar year. For example, January 1, 2023 through December 31, 2023.

What types of extramural activities must be reported?

All paid and unpaid activities that are not part of the faculty member’s assigned duties at Penn Medicine. Examples of extramural activity include, but are not limited to:

  • Service on advisory boards and committees
  • Providing services to a corporation, business, or industry as an individual officer, director, owner, or consultant
  • Providing services to an educational institution, or governmental agency as a scheduled lecturer or consultant
  • Providing services to a private foundation or professional or trade association as a consultant
  • Providing services as a voluntary expert witness in any civil or criminal case
  • Providing services as an editor or reviewer for professional journals
  • CME lectures not sponsored by Penn Medicine

You are not required to disclose any of the following:

  • Participation in local community activities such as religious institutions, schools, and clubs

Must I report outside work for pay that is not related to my area of professional expertise?

No, the reporting requirement only covers outside work in the area of expertise for which the faculty member is employed by the University of Pennsylvania. For example, a surgeon who is compensated for playing the piano in a local restaurant on Saturday night or who is paid to referee youth soccer games does not need to report such work. However, faculty members’ outside activities (whether paid or unpaid) may not interfere with the performance of their responsibilities.

Do I have to disclose the amount of money I received as payment for the extramural activity?

Yes, the exact dollar amount paid to you for extramural services is required to be reported. If you are unsure as to the exact dollar amount, an accurate estimation is required.

When is the form due?

The extramural disclosure form is to be completed based on the date communicated to you each year. For 2023, the form is due by July 29, 2024.

Is my Annual Extramural Reporting Form going to be made public?

Please be aware that on Aug. 1, 2013, the Centers for Medicare & Medicaid Services (CMS) began collecting industry payments data under the Physician Payments Sunshine Act (Sunshine Act). The payments that are reported to the federal government and published on a public website by CMS include consulting fees; honoraria; gifts; compensation for food, travel, education, or conferences; research funding; stock or stock options; investment income; royalties; and licenses. We would strongly encourage you to review the reported data to ensure its accuracy.

Do I need to report grant or clinical trial funding?

No, work supported by grant or contract funds awarded to the University of Pennsylvania or CHOP does not constitute extramural activity.

Do I need to report my VA appointment as an extramural activity?

No.

I have no change in my extramural activities since I reported last year. Must I still complete the disclosure form?

Yes, University policy requires reporting every year.

Does filling out the annual form satisfy all of my disclosure requirements?

No, while this annual form is retrospective in nature, the University IRB and the Office of Research Services (mandated by NIH) may ask you to fill out other electronic forms related to your financial interests in real time if you apply for a grant or a clinical trial.  Those forms need to be filled out accurately and completely.

When do I need to disclose my outside activities to my Department Chair?

All extramural activities should be reviewed with the Department Chair in advance of accepting the engagement.

What if I am uncertain as to whether or not I should disclose a particular outside activity or financial relationship?

If, after reading the questions on the disclosure form, you are unsure as to whether or not you should report an outside activity and/or financial interest, then you should err on the side of caution and disclose the information. If an issue should arise in the future, having reported the activity/relationship offers some protection to you and the University in terms of how the matter is perceived by others. Failure to report an activity, relationship, and/or financial interest may be misinterpreted as a desire to hide the activity. No one is criticized for “over-reporting.”

How many days can I perform consulting activities per year without violating the conflict of commitment policy?

Faculty members are permitted to consult up to one day per seven-day week on outside activities or consulting work, with advance permission from the Department Chair. Ten hours of activity equals one day.

When reporting time spent on extramural activities, do I have to include travel time?

Yes.

Must extramural activities performed during evenings and weekends be reported?

Yes, all extramural activities should be reported regardless of the day of the week or time of day when the services were performed.

How do I report extramural income that is received from a third party such as CME activities?

If a faculty member gives CME lectures for a pharmaceutical or device company, but the lectures are coordinated by a separate lecture arrangement/CME company which pays for expenses and sends 1099 forms to income recipients, then the faculty member should report pharmaceutical or device company on his/her annual reporting form if the payment source is easily attributable to that company, even though a 1099 was received from the separate lecture/CME company.

Should I report that I serve as President, Vice President, or on the Board of a company?

Yes, information about fiduciary roles is required to be reported.

What if I have an outside business, but the business operates at a loss. Should I report this?

Yes, self-employment or ownership and operation for a for-profit business should be reported regardless of profit or loss, if the business is related to your profession as a faculty member.

I do my consulting and outside activities through a Limited Liability Corporation that I formed for that purpose. Do I report these activities on the annual form?

Yes, you should report all consulting and outside activities regardless of whether the organization is an LLC, etc.

Do I need to report reimbursement for travel or hotel expenses that are paid by an outside entity?

Currently the University does not require the reporting of travel or hotel expenses that are paid as direct reimbursement for costs incurred by the faculty member.

I participate in a mutual fund. Do I need to report this on my annual form?

No, mutual funds are excluded from reporting.

May I use Penn Medicine resources in my consulting or other extramural activities?

Modest and incidental use of University resources (such as telephone, e-mail, photocopier, etc.) is permitted for extramural activities of faculty and staff. However, any activity that utilizes Penn’s resources, e.g. laboratories, clinical facilities or patients, is not extramural. If more than modest and incidental use of University resources is needed or desired, it is the obligation of the individual to contact the Department Chair to arrange (in advance) for proper compensation to the University if the Department Chair determines that the activity is appropriate. University staff should not be utilized in connection with extramural activities.

I am occasionally asked to serve as an expert witness in legal proceedings and am compensated for that service. Does this count as consulting?

Yes, since service as an expert witness does take time away from your primary responsibilities as a faculty member, the time devoted should be considered and reported as an extramural activity.

I still have questions. Is more information available?

Yes, please support@research.upenn.edu with any questions.

Questions? Contact support@research.upenn.edu

Want More Info? Try These

Grant Financial Management


Available now, manage your grant portfolio using Grant Financial Management (GFM)!

GFM provides researchers and administrative staff a streamlined approach to managing budgets and projections for their sponsored projects. For more information use the button below where a brief video introduction to the system is available along with other resources.


Research, Interests, and Activities


This new application provides Faculty with a single location for the disclosure of outside interests and activities and a method of conducting research-relatedness assessments, thereby facilitating the obligations as required by certain funding agencies and supporting compliance with Penn policies. Specifically, this tool will help identify and manage Financial Conflicts of Interest (FCOIs) and includes FCOI training.

RIA integrates with and leverages data from existing Penn systems, including Penn Community, PennERA, HS-ERA, Inteum, and the Research Inventory System (RIS) to simplify the disclosure process.