Obligation to Report Honoraria by May 15 under State Ethics Law

I write as the College Ethics Officer concerning the obligation of each employee under NY State Ethics Law to report the receipt of honoraria (which includes travel reimbursements). Click Here to see the regulations at the New York State Commission on Public Integrity’s Website: .  The report of honoraria received between April 1, 2008 and March 31, 2009 should be sent by Friday, May 15, 2009 to Kathleen Galvez, College Ethics Officer, 1A- 210 or by email to kathleen.galvez@mail.csi.cuny.edu. The information to be reported is found on the form at the bottom of this memorandum.
Examples of honoraria are a speaking fee or compensation received for writing an article, or reimbursement for travel expenses not related to official duties ( i.e., the service provided for which compensation is received is not related to your job). The regulations (19 NYCRR Part 930, 930.2) specifically define honoraria as follows:

a payment, fee or other compensation to a covered individual for services rendered by a covered individual not related to the covered individual’s official duties, which payment, fee, or other compensation is made as a gratuity, or as an award or honor (e.g., for delivering a speech, writing or authoring an article or publication, or attending a meeting or conference), and

a payment, whether to a lodging site or a provider of transportation, for travel expenses made to or on behalf of an individual, or reimbursement to the covered individual for travel expenses incurred, for such services rendered by a covered individual not related to the covered individual’s official duties.

Under these two definitions, for example, honoraria received by a faculty member for delivering a speech, writing or authoring an article or publication, or attending meetings or conferences within his or her discipline do not trigger the need to file a report.

You should seek prior written approval through the Office of the College Ethics Officer for receipt of an honorarium (including travel reimbursements). If you have any doubt concerning the propriety of accepting an honorarium, you should consult with the Ethics Officer and then consider whether to file a request for prior approval or not to accept the honorarium. If you receive prior written approval you are not required to file a report for that honorarium.

Certain honoraria (including travel reimbursements) are prohibited. These include honoraria from individuals, companies, organizations, unions, vendors, and contractors that negotiate with (e.g., unions), do business with, or are interested in doing business with the University or the College. The regulations, for example, prohibit vendor paid travel to view demonstrations of a vendor’s products or services. The prohibitions also apply to employees serving as board members, whether compensated or not, and officers of related entities (e.g., auxiliary enterprise board, college association, foundation) as part of their official duties or within the scope of their employment at the College. Travel reimbursements for such purposes, however, may be made by the College when appropriate.
Should you have any questions, feel free to contact me at 718.982.2355.

Annual Report of Receipt of Honoraria: April 1, 2008 to March 31, 2009

 

Note: Only those employees who actually receive honoraria must file a report.

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