Background on Individual Outside Interests
In order to disseminate their knowledge and expertise outside the institution, SOM faculty members engage in a variety of outside activities. While JHU supports and encourages these activities, it is important to recognize, that the interests and time commitment that may be associated with providing services under a private agreement to outside entities have the potential to conflict with one’s primary obligations to Johns Hopkins and to impact academic integrity and objectivity.
To address these risks and to comply with federal regulations, JHU and the SOM have adopted policies to ensure that research, teaching, and clinical practice are performed in compliance with federal rules and regulations, to maintain public trust in the integrity of JHU as research university. In furtherance of this goal, the Office of Outside Interests administers JHU’s Conflict of Interest and Conflict of Commitment policy for the SOM and JHM faculty and staff.
The institution’s policy requires disclosure of all outside activities (both paid and unpaid) related to one’s institutional responsibilities. Disclosures are used to assess conflicts of interest both with research and with other institutional responsibilities.
Outside Activities & Conflict of Commitment
JHU defines outside activities as, “The provision of services and time commitments for non-University activities that are based on the expertise and knowledge of the Covered Individual and reasonably appear to be related to the Covered Individual’s University responsibilities or activities; or may reasonably be deemed to significantly impact the Covered Individual’s ability to satisfy his or her University responsibilities and activities”. The SOM defines institutional responsibilities as being anything related to the biomedical field.
JHU defines conflict of commitment as, “An outside activity that may interfere with a Covered Individual’s responsibilities to the University or is of a nature that the activity may only be performed through the Covered Individual’s University role”. The primary duty of full-time faculty members is to the University. Determining whether a particular outside arrangement constitutes an acceptable or unacceptable commitment is the responsibility of the Covered Individual’s department director (or, in some cases, the division director).
Disclosure
The Johns Hopkins University Conflict of Interest and Conflict of Commitment policy applies to all covered individuals. The policy defines covered individuals as, “University officers, faculty, staff, and others who: (i) are compensated or otherwise supported by the University for their services; (ii) use, control, or assign to others the use of University facilities and resources, (iii) participate or engage in University Research, or (iv) teach at the University. Students and part-time faculty and staff are considered Covered Individuals when they meet any of the aforementioned categories.
School of Medicine faculty members and investigators conducting research at and under the auspices of the University are required to disclose their outside activities and/or interests to the Office of Outside Interests for review via eDisclose. Disclosure requirements may vary depending on one’s employment or appointment status, one’s relationship to research, and other factors.
eDisclose
All outside activity disclosures are submitted electronically via JHU’s eDisclose. eDisclose, is the sole means for disclosing outside activities and/or interests for review. First-time users who experience difficulty upon attempting to log in with their JHED credentials should contact policy@jhmi.edu to request an account.
- User Guides are available under the Help Desk tab of eDisclose for users of the system. If you need additional help, please contact us directly at policy@jhmi.edu.
Background on Institutional Outside Interests/Conflicts of Interests
The Johns Hopkins University’s Policy on Institutional Financial Conflict of Interests is entitled The Johns Hopkins University and The Johns Hopkins Health System Corporation Policy on Institutional Conflict of Interest.
An institutional conflict of interest (“Institutional COI”) occurs when a financial interest of the university or an institutional official, acting within his or her authority on behalf of the institution, may affect or appear to affect the research, teaching, clinical care, professional practice, business transactions, and other activities that support their core missions.
Potential conflicts of interest between the Institutions’ primary objectives and its financial interests must be identified and properly managed with policies and procedures that support integrity and advance the Institution’s missions.
Such conflicts occur most frequently in situations where a research project provides a direct benefit to an outside entity through evaluation, validation, trial or test of an invention, product, drug, service or technology, and the university holds a financial interest in the outside entity. Such financial interests include, but are not limited to, receipt of licensing payments or royalties from the outside entity, or an ownership interest in the outside entity.
If you would like to report an Institutional COI, please email policy@jhmi.edu