Annual Report of Receipt of Honoraria
|MEMORANDUM:||Office of Compliance Programs and Legal Affairs|
|TO:||Faculty and Staff|
|FROM:||Olga Dais, Esq., Executive Director|
|DATE:||May 9, 2014|
|SUBJECT:||Annual Report of Receipt of Honoraria (covered period 4/1/13 - 3/31/14)|
This is a reminder that all CUNY employees are required to comply with the law and regulations governing the receipt and reporting of honoraria, whether or not they have been designated a policymaker.
If you received any honoraria during the period April 1, 2013, through March 31, 2014, you are required to file the attached "Annual Report of Honoraria" with the Office of Compliance Programs and Legal Affairs (CPLA) in room 2H05 to the attention of Olga Dais, Esq. or by email to firstname.lastname@example.org. Please submit your report to CPLA by Friday, June 9, 2014. If you did not receive any honoraria, you do not have to submit this report.
New York State Joint Commission on Public Ethics (JCOPE) generally defines honorarium as a "speaking fee or compensation received from writing an article, or reimbursement for travel expenses not related to official duties." Additionally, compensation for delivering a speech, compensation for writing an article, compensation for serving on a panel and compensation that is made as a gratuity or an award of honor can be considered honoraria.
CUNY Employees Not Employed in Academic Titles
Non-academic employees of CUNY must seek prior approval in order to accept honoraria and must report the receipt of honoraria to their College's ethics officer. Two factors to keep in mind:
- Honoraria cannot be accepted for speaking or writing in an area that is related to the employee's CUNY duties.
- Honoraria cannot be received from a disqualified source (generally defined as an entity or individual seeking to do or actually doing business with CUNY, such as a vendor, or prospective vendor).
CUNY Faculty: Full Time and Adjunct
CUNY faculty are exempt from the restrictions on the receipt of honoraria. This exemption means:
- CUNY faculty do not need to seek approval to receive honoraria.
- CUNY faculty may receive honoraria from a disqualified source.
However, CUNY faculty must still report the receipt of any and all honoraria. The exemption for academic positions does not relieve faculty from the reporting requirement.
JCOPE, while defining honoraria as compensation for work unrelated to an employee's official duties, nonetheless does not exempt faculty from reporting receipt of all speaking fees; reimbursed travel expenses; or payments received for writing and/or presenting written materials.
CUNY Employees Designated as Policymakers
CUNY employees (in both academic and non-academic titles) who are designated as policy-makers (e.g. chairs, directors, deans, etc.) and who file a Financial Disclosure Statement ("FDS") must also report all honoraria in excess of $1,000 on their annual FDS.
Outside Activity Request Form
Also, attached is the "Outside Activity Request Form" which is used to report outside employment (more than $1,000), or for serving as a director or officer of a profit-making corporation, or serving in an elected or appointed public office (e.g., a school board member). All such requests are subject to approval by the President's designee (Olga Dais). If you have previously submitted an "Outside Activity Request Form" you do not have to submit another form. You do not have to submit for previously reported positions.
For further information you may review the rules on the New York State Joint Commission on Public Integrity's website at www.jcope.ny.gov.
If you have any questions regarding the memo, please give Ms. Dais a call at (718) 262-2140.
cc: President Keizs