NIH Ethics Advisory Committee (NEAC)
All requests which fall under NIH Ethics Advisory Committee (NEAC) jurisdiction must be submitted to the employee's IC Ethics Office. IC Ethics Office staff will review the package, confirm it is complete and appropriate, and forward it to the NIH Ethics Office for consideration by NEAC. For detailed instructions for submitting Outside Activities or Awards, see the specific instructions listed on the Procedures page. Activities which fall under the jurisdiction of the NEAC include the following:
All Outside Activities and Awards from Outside Organizations for:
- OD Senior Staff
- IC Directors
- IC Deputy Directors
- Scientific Directors
- Clinical Directors
- Extramural Directors
All other NIH employees for:
- Outside awards that confer gifts valued equal to or greater than $2,500
- Outside activities where expected compensation is greater than $10,000 or expressed as an income stream, excluding travel expenses
- Outside activities with compensation as stock or stock options
Exceptions to NEAC Review Jurisdiction for Outside Activities
Presumed Approved Activities Previously Reviewed By NEAC. Ongoing outside activities are reviewed and approved for a one-year period unless a shorter duration has been stated in the request. Outside activities that extend beyond a one-year approval period must be resubmitted for renewal no later than 30 days prior to the expiration of the approval period.
An exception to NEAC jurisdiction allows an outside activity request to be renewed and approved by the IC DEC. The IC DEC may review and approve a request to renew an outside activity in each of the two years following the last NEAC recommendation provided the outside activity meets the criteria set forth below. After two years of IC review, a request to continue the outside activity re-enters NEAC jurisdiction for review and recommendation for approval or disapproval by the NIH DEC. If the NIH DEC approves the outside activity, it will again be eligible for 2 years of IC DEC approval. Outside activity requests reviewed by NEAC and approved by the NIH DEC within the 12 months immediately preceding the effective date of this policy are eligible for IC DEC review and approval under this exception.
This exception covers activities that meet the following criteria:
- The activity is Presumed Approved as defined in Section F of the NIH Manual Chapter 2400-06.
- The activity was last reviewed by NEAC, provided the last NEAC review occurred not earlier than 12 months prior to this policy’s effective date; and
- All of the following conditions are met:
- There is a supervisory statement indicating that there is no substantial change in the employee’s official responsibilities since NEAC’s previous consideration of the outside activity; and
- There is an employee statement indicating that there is no substantial change in the scope of the outside activity, compensation levels (except for incremental increases or decreases due to market conditions), and time commitment; and
- The following required documentation is included in the outside activity renewal request:
- A completed form HHS-520, “Request for Approval of Outside Activity”;
- The employee’s current position description;
- Form NIH-2657, “Supplement to Form HHS-520 Request for Approval of Outside Activity”, if applicable;
- When appropriate for clinical fellows, Supplemental Attachment to HHS-520 “Request for Approval of Outside Activity” NIH Fellows Providing Patient Care (e.g. Moonlighting);
- A syllabus, outline, summary, synopsis, or similar description of the content and subject matter of the proposed teaching, speaking, writing, editing activity, if applicable;
- Documentation, where relevant, that the employee is in compliance with restrictions on the use of his/her title and NIH affiliation. Note: Documenting that the employee has been advised does not satisfy this criteria; and
- Other relevant information including the outside employment contract, agreement, or invitation letter. Note: The contract, agreement, or invitation letter to engage in the outside activity may be the initial document and not a newly issued one if the initial document stated that the activity was for a prescribed period of time, i.e., for an established term of office.
Clinical Practice for New Employees. New NIH employees seeking to engage in clinical practice where total compensation exceeds or is anticipated to exceed $10,000 (including past and anticipated earnings) may submit a hard copy HHS-520 to be reviewed and approved by the IC DEC. This approval will be valid for 90 days to allow the employee sufficient time to complete another HHS-520 via NEES, and to be reviewed by NEAC and receive the NIH DEC’s determination with respect to the activity.
The NEAC meets approximately every two weeks. See NEAC meeting dates. See also specific instructions for submitting an Outside Activity request or for submitting a request for approval of an outside award. Contact your IC's Ethics Official for questions.