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2319.3 Limited Engagement Policy

Document purpose

The purpose of this policy is to define Limited Engagement and outline the policy for paying of Limited Engagement fees.

effective

January, 2017

revised

February, 2026

Reviewed

February, 2026

Responsible Office

Procurement Services

Approval

Procurement Services

Definitions

Limited Engagement

A Limited Engagement (LE) is a subset of independent contractor services and defined as a payment to an individual for providing a low-risk service of an academic nature, short duration, typically less than 30 days that meets the following criteria:

  1. The individual is engaged to perform a qualifying LE service (see the Penn LE Service Types table below);
  2. The individual is not a University student or employee performing services within the scope of their role as a University student or employee;
  3. The total payment does not exceed the maximum transaction amount, if applicable; and
  4. The engagement is limited in scope and duration (typically 30 days or less).

Penn LE Service Types

 

Service Type Maximum Total Payment Definition/Examples
Guest Speaker n/a Expert or professional who delivers a talk or presentation at an event.
Guest Lecturer n/a An academic or professional expert who charges a fee to deliver a lecture, or a limited series of lectures, but does not have student grading or assessment responsibilities.
Artist n/a Individuals providing artistic services such as exhibitions, stage/set design, choreography, or costume design.
Performer n/a DJ, singer, comedian, dancer, musician, actor, magician, juggler, circus performer, or performance painter.
Writer/Editor n/a Individuals who write or edit grants, manuscripts, articles, or act as manuscript reviewers.
Board Member n/a Individuals compensated for their duties as advisory or directory board members.
Critic n/a Individuals paid to critique or judge artistic, literary, or academic works or competitions.
Preceptor n/a Experienced professionals who supervise or train students or trainees in a practical, hands-on environment but does not have student grading or assessment responsibilities.
Mentor (Academic) n/a Faculty, researchers, or professionals who advise and support students, junior faculty, or scholars in academic development but does not have student grading or assessment responsibilities.
Low Risk, Low Dollar  

 

 

 

 

 

 

 

$5,000

 Limited-scope services that do not serve a critical function to the University, subject to review and approval by Procurement Contracting based on all relevant factors including, but not limited to, the following:

  1. No Work Involving Minors
    • The individual will not have direct or unsupervised interaction with non-student minors (e.g., K-12 students).
  2. Low Data Risk
    • The engagement does not involve access to any University data or systems classified as Moderate or High Risk under Penn’s Data Risk Classification.
    • Only data intended for public dissemination or otherwise classified as Low Risk may be accessed, received, or generated.
    • The engagement does not grant credentials, permissions, or other access to institutional systems.
  3. Low Likelihood of Personal Injury or Property Damage
    • The service is performed in a manner and environment that presents a low likelihood of physical harm to the individual or others, and does not involve:
      • use of hazardous materials, specialized equipment, or laboratory environments requiring safety training or supervision;
      • activities with athletic, mechanical, or environmental hazards; or
      • work in locations or conditions that pose unusual risks to health or safety.
  4. No Material Regulatory, Legal, or Reputational Risk
    • The engagement does not involve human-subjects research, export-controlled materials, protected health information, or other regulated activities.
    • The service is unlikely to create institutional exposure under University, federal, or state regulations, or to adversely affect Penn’s reputation if performed as expected.

Policy

A Limited Engagement fee may only be paid to individuals who meet the criteria listed above. It cannot be paid to a student, an honoraria recipient, a human subject recipient, or any employee of the Trustees of the University of Pennsylvania or any of its entities engaged within the scope of their role as a University employee.

The Limited Engagement Agreement must be completed and signed by the individual providing services and submitted to Procurement Contracting through BenHelps for review and approval signature. The agreement should be executed prior to the individual’s performance of service.