NIH Employees' Participation with Professional Organizations
The purpose of this webpage is to provide ethics guidance to NIH employees and to representatives of professional organizations regarding NIH employees’ participation with such organizations.
While the institutional and personal benefits gained from having NIH employees play active roles in related non-federal organizations are many, that participation must be in a manner that protects and promotes the public trust, is free of any conflicts of interest, and complies with federal rules, regulations, and policies.
Being active in professional organizations often serves the interests of the organizations and NIH, and is also a personal right we hold as individuals. Many organizations have goals that serve to benefit the NIH’s interests either by enhancing the skills of our employees, serving as vehicles by which substantive programmatic information is exchanged, and/or engaging in projects and programs that complement the NIH’s activities. When such mutual interests exist, an NIH employee is encouraged to seek approval from his or her supervisor to serve as part of his or her official duties. When participation is not considered part of an employee’s official job responsibilities and involves his or her general scientific or professional expertise, the employee is encouraged to request permission for an outside activity to be performed in his or her personal capacity in accordance with agency prior approval requirements. If outside activity approval is granted, NIH resources may not be used to support the activity, and the activity must be performed during the employee’s personal time.
Whether an individual employee participates as an Official Duty Activity, as a Federal Liaison, or as an Outside Activity is examined on a case-by-case basis with determinations made based on the specifics of each case.
Official Duty Activities: NIH employees may be invited to participate in a variety of activities with outside professional organizations. Employees may be invited to provide input or advice based on their expertise, attend meetings, make presentations, or other similar involvement. The employee is responsible for identifying sources of potential conflicts of interests with the outside organization prior to engaging in an activity. Most activities require supervisory approval. Some activities require further approval by the employee’s Deputy Ethics Counselor (DEC). The duration may be one-time or of a lengthier timeframe.
To assist NIH employees with their efforts to participate officially in non-Federal organizations, NIH offices may make available official time and may provide travel funds or other resources to attend meetings of non-Federal organizations. A few points to note:
- An NIH employee must not participate in business or financial matters of an outside organization;
- Fundraising or lobbying during official duty hours using official resources is prohibited;
- An NIH employee must not accept compensation from the organization for his/her official NIH work with the organization;
- Both the employee and the outside organization may use the employee’s official title and NIH affiliation as a reference or identifier;
- Pursuant to a recent change in policy, an NIH employee may obtain approval to serve in a leadership position (e.g. officer, director, trustee, or other position or role having the same legal responsibilities and characteristics) of a 501(c) nonprofit professional organization as an official duty. He or she must obtain approval from his or her supervisor, receive ethics guidance regarding his or her participation, provide the guidance to the organization, and obtain approval from his or her Deputy Ethics Counselor (DEC) with concurrence from the NIH Ethics Office (NEO). The policy and related guidance is available here.
Federal Liaison Activities: For some activities with outside organizations, it is important that an employee formally represent the interests of NIH. When an employee will present information on behalf of NIH and serve as a spokesperson for NIH policies or programs with an outside organization, he/she may request approval to be designated as a Federal Liaison to the organization.
- A Federal Liaison is a non-voting, non-fiduciary representative of the NIH to the outside organization.
- An employee serving in this capacity must not participate in the internal business-related affairs, or fundraising activities of the outside organization.
- An employee may participate as a Federal liaison on Government time, use Government equipment and services, and travel on Government travel orders.
- Both the employee and the outside organization may use the employee’s official title and NIH affiliation as a reference or identifier.
Outside Activities: Outside activities involve the employee’s general scientific or professional expertise and require agency approval. For example, employees require prior approval to serve as an officer or member of a Board of Directors of a professional organization. If the activity will likely involve participation in the organization’s business affairs (such as finance or personnel), and/or fundraising, then an employee should seek approval for the activity in his or her personal capacity as a private citizen.
- The employee must disqualify him/herself from participation in any official NIH matters involving the outside organization.
- The employee may not represent the organization to the government on behalf of anyone else with the intent to influence.
- The outside activity work must be conducted on his/her personal time, without use of NIH resources.
- The employee must comply with rules regarding reference to official position and title.
For additional information on each of these options, and to compare and contrast these methods of participation, refer to the side-by-side comparison chart.