Conflict of Interest
An outside financial or fiduciary interest can create conflicts with one’s research or other Johns Hopkins activities.
Conflicts of Interests can arise when you are conducting research that is sponsored by or involves a product controlled, manufactured, or sold by a company
- For which you are consulting or providing other outside services
- In which you have a personal financial interest
- For which you have a fiduciary responsibility
- In which your spouse/domestic partner and/or minor dependent has a financial interest or a fiduciary responsibility
Similarly, conflicts of interest can also arise when you are conducting research involving a product for which you are named an inventor on a related license.
Many conflicts of interest can be successfully managed with measures designed to protect the integrity and objectivity of your research and other professional endeavors. For a determination to be made, there must be full disclosure to the Office of Policy Coordination. Some conflicts of interest are reviewed by the Committee on Outside Interests (COI), whose members are appointed by the Dean.
The NIH recently asked the School of Medicine (SOM) to modify the Policy on Conflict of Interest (COI) in accordance with certain specific provisions of 42CFR Part 50 Subpart F and related guidance published by NIH. The revisions were prepared by the Office of Policy Coordination (OPC) in consultation with the Office of the General Counsel and the Vice Provost for Research. They pertain exclusively to administrative issues such as record keeping, reporting to PHS awarding agencies, conflict of interest reporting by sub-recipients, and the University’s procedures for addressing failure to comply with NIH reporting requirements under federal regulations. The revisions will not affect current COI review procedures for SOM investigators. The revised policy takes effect immediately. The full text is available on the School of Medicine Faculty Policies page.
Any questions should be addressed to the Office of Policy Coordination.
Professional Commitment
The primary duty of full-time and salaried part-time faculty is to the University. An outside arrangement must therefore involve a time commitment that is reasonable in relation to one’s faculty duties and may not involve services or conditions that conflict with institutional policies.
Professional commitment may arise when any of the following is present:
- Excessive time spent consulting or providing outside services
- Use of the JHU name by another party in connection with private outside activity
- Use of JHU facilities or resources in connection with private outside activity
- Restrictions on academic freedom related to a private outside activity
Determining whether a particular outside arrangement constitutes an acceptable or unacceptable commitment is a joint responsibility of the faculty member’s department director (or, in some cases, the division director) and OPC. The Dean’s office provides department directors data on the proposed time commitment and the nature of proposed activity disclosed to OPC. These data help them assess the potential for conflict of commitment generated by the activity.
Faculty and staff must disclose all outside activities in eOPC for review of conflict of commitment, regardless of whether the service involves remuneration.
Any questions should be addressed to the Office of Policy Coordination or your Department Director.
