Financial Conflicts of Interest

The Johns Hopkins University maintains the highest principles of integrity in research, education, service, and clinical care.  Generating new knowledge and transferring it for the benefit of society often require interaction with commercial and other organizations outside the University.  To advance knowledge and support its academic missions, the University supports and encourages many types of relationships with a wide variety of outside organizations.  However, some arrangements can give rise to conflicts of interests in research and may create actual, potential, or perceived risks to research integrity, objectivity, or the safety of research subjects.  In order to ensure that these arrangements are consistent with institutional policies and applicable regulations, they must be disclosed to the University and reviewed under the institution’s conflict of interest policies.  This website contains information about the University’s policies on conflict of interest in research and disclosure and professional commitment as well as about the University’s online disclosure system.

Johns Hopkins COI and COC Disclosure Infromation

All units of Johns Hopkins University are governed by the Conflict of Interest and Conflict of Commitment Policy except the Applied Physics Lab. The policy is uniformly applied by all schools and divisions of the university.

If you are a full-time or salaried part-time JHU faculty member, select the division of your primary faculty appointment to access the information that applies to you:

JHU Staff Member

JHU staff members who are not investigators on research at Johns Hopkins or under Johns Hopkins auspices are not required to disclose under the conflict of interest policy.   They are subject to other policies, including the JHU Policy on Conflict of Interest and Conflict of Commitment. 

JHU staff members who are investigators on research at Johns Hopkins or under Johns Hopkins auspices must disclose the financial interests below if they are related their institutional responsibilities.

Outside Activities

The following outside activities must be disclosed by full-time and part-time salaried SOM faculty members when they are provided to an entity, whether for-profit or not-for-profit if the activity relates to your Johns Hopkins responsibilities and regardless of whether remuneration has been received and/or is anticipated. Examples of these activities may include:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed if the interest is related to your Johns Hopkins responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your institutional responsibilities. 

Reimbursed or Sponsored Travel

JHU covered individuals who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Employee of Howard County General Hospital, Inc., Suburban Hospital, Sibley Memorial Hospital, or Johns Hopkins Community Physicians

Employees of Howard County General Hospital, Inc., Suburban Hospital, Sibley Memorial Hospital, or Johns Hopkins Community Physicians who are not investigators in any research are not required to disclose.

Employees of Howard County General Hospital, Inc., Suburban Hospital, Sibley Memorial Hospital, or Johns Hopkins Community Physicians who are investigators in any research must disclose, on an annual basis, the outside activities and financial interests listed below if they are related to their Johns Hopkins institutional responsibilities.

Outside Activities

The following outside activities and associated remuneration must be disclosed when they are provided to any entity, whether for-profit or not-for-profit) and are related to your Johns Hopkins institutional responsibilities:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager

The following outside activities must be disclosed when they are provided to any entity, whether for-profit or not-for-profit, and are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your Johns Hopkins institutional responsibilities. 

Reimbursed or Sponsored Travel

Employees of Howard County General Hospital, Inc., Suburban Hospital, Sibley Memorial Hospital, or Johns Hopkins Community Physicians who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to your Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification Employees of Howard County General Hospital, Inc., Suburban Hospital, Sibley Memorial Hospital, or Johns Hopkins Community Physicians who are investigators are not required to complete an annual certification.  However, these individuals are required to update their disclosures on an annual basis.

Employee of All Children’s Hospital

Employees of ACH who are not investigators on a Johns Hopkins Medicine (JHM) ACH IRB protocol and/or JHU research project are not required to disclose.

Employees of ACH who are investigators on a JHM ACH IRB protocol and/or JHU research project must disclose the financial interests below if they are related to their institutional responsibilities.

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and they are related to your institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your institutional responsibilities. 

Reimbursed or Sponsored Travel

Employees of ACH who are investigators on PHS-funded JHU research must disclose occurrences of reimbursed or sponsored travel that are related to their institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute. 

Annual Certification

Employees of ACH who are investigators are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

Employee of University of South Florida (USF)

Employees of USF must adhere to the USF Policy on Individual Conflicts of Interest in USF System Research Projects and USF System Financial Conflicts of Interest (FCOI).

Employee of a Johns Hopkins Clinical Research Network (CRN) member organization (Anne Arundel Health System Research Institute, Greater Baltimore medical Center, INOVA Health System, and Peninsula Regional Medical Center)

Employees of a Johns Hopkins CRN member organization who are not investigators on a JHU IRB protocol and/or research project are not required to disclose.

Employees of a Johns Hopkins CRN member organization who are investigators on a JHU IRB protocol and/or research project must disclose the financial interests below if they are related to their Johns Hopkins institutional responsibilities.

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your Johns Hopkins institutional responsibilities. 

Reimbursed or Sponsored Travel

Employees of a Johns Hopkins CRN member organization who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification

Employees of a Johns Hopkins CRN member organization who are investigators are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

Employee of the Kennedy Krieger Institute (KKI) or the Lieber Institute (Lieber)

Employees of KKI or Lieber who are not investigators on a JHU IRB protocol and/or research project are not required to disclose.

Employees of KKI or Lieber who are investigators on a JHU IRB protocol and/or research project must disclose the financial interests below if they are related to their Johns Hopkins institutional responsibilities.

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and they are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your Johns Hopkins institutional responsibilities. 

Reimbursed or Sponsored Travel

Employees of KKI or Lieber who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification Employees of KKI or Lieber who are investigators are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

Employee of or Faculty in the Johns Hopkins Berman Institute of Bioethics

Employees of the Berman Institute who are not investigators on a JHU IRB protocol and/or research project are not required to disclose.

Employees of the Berman Institute who are investigators on a JHU IRB protocol and/or research project and individuals with a Berman-only faculty appointment must disclose the financial interests below if they are related to their Johns Hopkins institutional responsibilities.  (Individuals who have a JHU faculty appointment should select the appropriate division above to view their disclosure requirements.)

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and they are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your Johns Hopkins institutional responsibilities. 

Reimbursed or Sponsored Travel

Individuals who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification Individuals associated with the Berman Institute are not required to complete an annual certification unless these individuals also have a JHU faculty appointment.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

Investigator on a JHU protocol and/or research project (no JHU employment or appointment)

Investigators on a JHU IRB protocol and/or research project must disclose the financial interests below if they are related to their Johns Hopkins institutional responsibilities.

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and they are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your institutional responsibilities. 

Reimbursed or Sponsored Travel

Investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification Investigators on a JHU IRB protocol and/or research project are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

Subrecipient investigator (investigator on a JHU sub-award to another entity)

If the subrecipient maintains an up-to-date, enforced policy on FCOI pursuant to 42 C.F.R. 50.604(a), subrecipient investigators must adhere to the subrecipient’s disclosure and conflict of interest policies.  

If the subrecipient does not maintain an up-to-date, enforced policy on FCOI pursuant to 42 C.F.R. 50.604(a), subrecipient investigators on a JHU IRB protocol and/or research project must disclose the financial interests below if they are related to subrecipient’s work for JHU:

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your institutional responsibilities. 

Reimbursed or Sponsored Travel

Subrecipient investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to subrecipient’s work for JHU, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification Subrecipient investigators are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.

JHU student or post-doctoral trainee

JHU students and post-doctoral trainees who are investigators on a JHU IRB protocol and/or research project must disclose the financial interests below if they are related to their Johns Hopkins institutional responsibilities.

Outside Activities

The following outside activities must be disclosed when they are provided to an entity, whether for-profit or not-for-profit, and they are related to your Johns Hopkins institutional responsibilities, if remuneration has been received and/or is anticipated:

• Consulting
• Scientific advisory board, committee, or review panel service
• Speaking, teaching, and lecturing
• Board of Directors service
• Officer
• Manager
• Publishing
• Editing
• Authoring

Exceptions.  The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:

• Scientific advisory board, committee, or review panel
• Speaking, teaching, and lecturing

Financial Interests

The following financial interests in any entity, whether for-profit or not-for-profit, must be disclosed, provided they are related to your Johns Hopkins institutional responsibilities:

• Inventor of licensed technology
• Entitlement to equity and/or royalty
• Receipt of income from licenses, whether equity, royalty, or other
• Equity ownership, regardless of how the equity is acquired (not including mutual funds)

The financial interests of one’s spouse, domestic partner and/or minor dependents also must be disclosed if they are related to your institutional responsibilities. 

Reimbursed or Sponsored Travel

JHU students and post-doctoral trainees who are investigators on PHS-funded research must disclose occurrences of reimbursed or sponsored travel that are related to their Johns Hopkins institutional responsibilities, regardless of the relationship of the travel to PHS funding, when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity.  (Note:  This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.)  This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute.  Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.

Annual Certification JHU students and post-doctoral trainees who are investigators are not required to complete an annual certification.  These individuals may, however, be required to update individual disclosures on an annual basis, as indicated as a condition in the disclosure’s review outcome.