NIH employees make numerous outstanding contributions to the biomedical sciences, often of such merit that these employees are honored by colleges and universities which award them an honorary degree. An employee may receive most honorary degrees given for the employee’s professional contributions and/or accomplishments within the employee’s respective career or occupational field. The NIH recommends that awards and honorary degrees be accepted on either official duty or on personal time (approved leave). An honorary degree is considered an exception to the rules regarding gifts from outside sources. Advance permission must be obtained via the Approval of Honorary Degree form, available on the NIH Ethics Program web site (see below). The following guidelines apply to the acceptance of honorary degrees.
Approval by a Deputy Ethics Counselor:
An employee may accept an honorary degree from an institution of higher education based on a written determination by a Deputy Ethics Counselor (DEC) that the timing of the awarding of the degree will not cause a reasonable person to question the employee's impartiality in any matter affecting the institution. For example, the DEC will verify whether there are any pending lawsuits, investigations, grant or contract applications or disputes, or other similar matters, involving the institution conferring the degree or the employee to whom the degree is offered. If such pending matters exist, a determination will have to be made, based upon the circumstances, as to whether the pending matter is such that the employee may accept the honorary degree.
Disqualification:
To avoid any appearance of a conflict of interest, an employee must be disqualified from all matters involving the institution awarding the degree from the date that the employee is notified of the honorary degree until the date the degree is conferred.
Official Duty Activity :
It is recommended that the employee accept an honorary degree as an official duty activity. No separate official duty request is necessary. The employee may also use approved leave to accept the degree.
Honorary Degrees from Foreign Governments:
The Foreign Gifts and Decorations Act (FGDA) (5 USC 7342(d)), provides congressional consent to the receipt of decorations from public universities operated by a foreign government. The Department of Justice has interpreted decorations to include honorary degrees. [Federal employees are prohibited from having an outside activity with a foreign public university by the emoluments clause in the US Constitution. But receipt of an honorary degree is not an outside activity and there is no receipt of a "present, Emolument, Office, or Title from" the foreign government.]
For More Information:
For additional guidance, contact your IC's Ethics Office staff(
,4 pages) or see NIH Manual Chapter 2400-10 Gifts From Outside Sources (pending release).
Documentation -- Honorary Degree Approval Form:
The HHS Honorary Degree Approval form is used to capture the information needed for an approval of an honorary degree by an NIH employee. The form is available on the NIH Ethics Program web site forms page.
For additional information, contact your IC's Deputy Ethics Counselor or Ethics Coordinator.