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Institutional policies require that outside activity and financial and fiduciary interests be disclosed for two reasons. Disclosures must be reviewed for conflicts of interest with research and conflicts of interest with other Johns Hopkins responsibilities. Faculty members’ disclosures also are reviewed for compliance with the professional commitment policy. Disclosure requirements vary depending upon one’s employment status, appointment, and involvement in research. The policies and review processes are described below.
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 a joint responsibility of the faculty member’s department director (or, in some cases, division director) and the Outside Interests division of the Office of Policy Coordination (OPC). Outside commitments are reviewed for compliance with institutional policies and standards, including:
- Time commitment
- Conflict of commitment with Johns Hopkins duties
- Use of the Johns Hopkins name by or in connection with an outside activity
- Use of Johns Hopkins facilities and resources
- Academic freedom
- Regulated activity, such as provision of clinical care outside the institution
Objectivity in research is a core scientific value. Johns Hopkins policies are designed to protect against risks to objectivity associated with financial conflicts of interest. To facilitate review of financial interests in research and to comply with federal regulation, faculty members and all investigators must disclose personal financial interests that reasonably appear to be related to their institutional responsibilities. Detailed disclosure requirements can be found here.
A conflict of interest may arise when a financial interest is related to one’s research and may affect or appear to affect the objectivity of the research, the safety and welfare of human research subjects, or the interests of students and trainees. A conflict of interest also may arise if a financial interest has the potential to affect one’s responsibilities other than research, such as teaching, clinical practice, or administrative duties.
A disclosed financial interest is considered related to one’s research if the research could impact the value of the company in which the financial interest is held (or from which it derives) or the value of its products or those of its competitors. If the financial interest is related to one’s research and it has the potential to impact the objectivity of the research, the safety of human research subjects, or the rights and interests of students or trainees, there is a conflict of interest. Under PHS regulation, when the institution determines that a financial interest is related to PHS-supported research and “could directly and significantly affect the design, conduct or reporting” of the research, the institution has identified a financial conflict of interest (FCOI). The FCOI must be eliminated or managed to protect the integrity and objectivity of the research. Many conflicts of interest can be successfully managed with measures designed to protect the integrity and objectivity of research and other areas of risk. However, some financial conflicts of interest cannot be managed and the financial interest needs to be reduced or eliminated in order for the researcher to participate in the project.
Questions should be addressed to the Office of Policy Coordination.