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March 7, 2011

NOTES -- DEC/EC Meeting
Monday, March 7, 2011 -- 11:00 – 12:00
Bldg.  50, conference room 1227 & 1233

Items for Discussion/Presentations:

  1. Hours for 520 – verification and tracking: When reviewing a 520, consider the hours being proposed.  While it is not within the Ethics Official’s responsibility to assure that the requisite leave is ultimately taken, the hours proposed on the 520 should make sense, for example, when considering the employee’s work schedule or the amount of compensation being offered.
  2. Foreign Private Foundations: Outside activities with foreign private foundations raise two issues: compensation and travel.

    If the entity is a private foundation under the US tax code, then certain highly paid employees may not receive compensation from the foundation. This may be the case for foreign private foundations as well. However, foreign private foundations are not typically listed as such on the IRS Publication 78 website ( To determine if the tax on self-dealing applies to payments from a private foreign foundation, contact the foundation’s counsel. Unless it receives substantially (85% or more) all of its resources/support comes from outside the US, the tax will apply.

    If it is a private foundation, travel reimbursement may be accepted. However, the exception only permits reimbursement if the travel is WITHIN the US – opposite of the Foreign Gift and Decorations Act exception (for travel wholly outside of the US).

  3. Awards Analysis Sheet: Reminder, this analysis sheet is not required, but the information on it is. Please do not send an award package to the NEO unless all of the required information has been collected. Do not send incomplete packages. Rather, please call your NEO point of contact for help.
  4. Amendments to HHS Supplemental Regulations: We are continuing to work on NIH’s proposals and will keep you apprised. All comments are welcome and should be addressed to Zi-Xiang Shen.


  1. Call for NEAC Ex Officio Members: Send your name to Felecia Taylor
  2. WAGs: please use current form (on website)
  3. OGE Conference Topics & Speakers: Please let Genia Bohrer know if you have submitted a suggestion.

Posted 4/12/11