All outside activities and interests are reviewed for conflict of commitment and conflict of interest. Under School of Medicine Conflict of Interest policy, financial and fiduciary interests are generally categorized as follows:
No Financial Interest
- Remuneration for services is $0
- No ownership of company stock or stock options
- No running or future royalties from company
- No other payment or remuneration of any kind
Minimal Financial Interest
- Remuneration for services is above $0 and below $25,000 per year
- No ownership of company stock or stock options
- No running or future royalties from company
Significant Financial Interest*
- Remuneration for services is above $25,000 per year; and/or
- Ownership of company stock or stock options; and/or
- Running or future royalties from company
Fiduciary Interest
- A role in the company involving a fiduciary obligation, e.g., to maximize the value of shareholders’ interests (Examples include roles on a board of directors, as an officer, or as a manager)
* Please note that PHS regulation (42 CFR Part 50 Subpart F) defines "Significant Financial Interest" as anything of monetary value, including but not limited to:
- salary of other payments for services (e.g., consulting fees or honoraria);
- equity interests (e.g., stocks, stock options or other ownership interests);
- intellectual property rights (e.g., patents, copyrights and royalties from such rights).
The term does not include:
- salary, royalties, or other remuneration from the Institution;
- any ownership interests in the Institution, if the Institution is an applicant under Phase I of the SBIR and STTR programs
- income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
- income from services on advisory committees or review panels for public or nonprofit entities
- an equity interest that, when aggregated for the Investigator and the Investigator's spouse and dependent children, does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a five percent ownership interest in any single entity;
- salary, royalty or other payments that when aggregated for the Investigator and the Investigator's spouse and dependent children over the next twelve months, are not expected to exceed $10,000.
Financial Interests and Your Research
Your financial interest in an entity could impact your research in a variety of ways depending on two factors:
- The nature and magnitude of your financial interest (minimal or significant)
- The nature of your related research (basic, animal, human subject research)
Fiduciary Interests and Your Research
Your fiduciary responsibilities for an entity could impact your research in a variety of ways depending on two factors:
- The type and structure of the entity (publicly traded, privately held, start-up)
- The nature of your related research (basic, animal, human subjects research)
If you have any questions, please contact us at (410) 516-5560 or email us at policy@jhmi.edu. We are available to give presentations about conflict of interest, conflict of commitment and/or outside services to departments, laboratories or faculty groups. We are also available to meet individually with faculty and staff who have general questions about outside activities, conflict of interest and/or conflict of commitment. |
