This policy applies to the Bloomberg School of Public Health, Krieger School of Arts and Sciences, School of Medicine, School of Nursing, and Whiting School of Engineering. (1)
The Policy on Disclosure and Professional Commitment contains the following sections:
- Activities and Interests to be Disclosed
- Disclosure Submission and Review Procedures
- Review and Management of Outside Commitments
- Review for Conflict of Interest
- Activities Subject to Additional Conditions or Limitations
- Time Limit
- Sanctions for Non-compliance
Effective August 24, 2012.
Additional revisions adopted November 14, 2012.
Clarifications incorporated May 8, 2014.
For a printable version of this Policy, click here.
As the University is devoted to the development and advancement of knowledge in a variety of fields, faculty members and other investigators engage with industry, government, professional associations, and other organizations (e.g., foundations) to further their knowledge and research, and to contribute to the richness and diversity of the academic community.
These relationships are governed by core principles:
Each member of the faculty of the Johns Hopkins University has an obligation to act in the best interest of the University and in furtherance of the University’s mission. Faculty must not let outside activities or interests interfere with those obligations. Outside activities are considered a privilege for which one must seek approval from the department director or chairman or his or her designee and fully report the activity to the University. (2)
It is the fundamental premise of this policy that faculty are expected to devote their primary professional loyalty, time, and energy to their teaching, research, service (including patient care for many physicians), and administrative responsibilities at the University.
This policy applies to all full-time and salaried part-time faculty members at The Johns Hopkins University Schools of Arts and Sciences, Engineering, Medicine, Nursing and Public Health. Individuals governed by this policy other are referred to as “covered parties.” Faculty members at other University divisions must comply with the JHU Policy on Conflict of Interest and Conflict of Commitment.
Full-time faculty members recognize that their primary responsibility is to The Johns Hopkins University. Acceptance of a full-time appointment entails an intellectual commitment to the furtherance of the academic objectives of the University and the School in which they have a primary appointment. Full-time faculty should assign first priority to the needs and goals of The Johns Hopkins University.
Salaried faculty whose appointments are less than full-time are expected to devote professional loyalty, time, and energy to their teaching, research, service, and administrative responsibilities, in accordance with their agreed-upon time commitments.
The specific responsibilities and professional activities that constitute an appropriate primary commitment should be based on an understanding between the faculty member and his or her department director. (3)
Non-salaried part-time faculty at the School of Medicine should refer to the Blue Book for applicable policies.
Other individuals may be governed by this policy in full or in part pursuant to contractual arrangements between the Johns Hopkins University School and other entities. This includes investigators on sub-awards from Johns Hopkins, with modifications specified below.
Disclosures made pursuant to this policy will be reviewed, as appropriate, for conflicts of interest with both research and other professional activities. These reviews will be governed by Division and University policies on conflict of interest.
The JHU Schools of Arts and Sciences, Engineering, Medicine, Nursing and Public Health must follow this policy or adopt policies that are consistent with this policy.
B. Activities and Interests to be Disclosed
A covered party must disclose any of the following time commitments and/or financial interests listed below that reasonably appear to be related to his/her institutional responsibilities. Unless otherwise noted, the disclosure requirement also applies to the financial interests of the covered party's spouse, domestic partner, and dependent children if their interest(s) are related to the covered party's institutional responsibilities.
Services to outside entities, including any income or remuneration that will be received, that may be reasonably related to one's institutional responsibilities. (4) Institutional responsibilities are those activities for which one is employed or appointed by the University. Examples may include but are not limited to research, teaching/education, service or practice, and administrative responsibilities.
- This includes, but is not limited to: consulting, scientific advisory board service, honoraria for lecturing, and compensated "expert witness" consulting and testimony.
- Services must be disclosed, whether they are undertaken by agreement with for-profit or not-for-profit organizations or with non-U.S. government agencies.
- Services to U.S. government agencies, other than those services listed below as exclusions, must be reported.
- Services to an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institute of higher education, other than those services listed below as exclusions, must be reported.
- Disclosures should specify the name of the entity to which the service was provided, not the name of an intermediary organization engaged to handle logistics or payment.
- This does not include:
- Services to the Johns Hopkins University, the Johns Hopkins Health System Corporation, or any of their constituent entities.
- Services governed by an agreement between the Johns Hopkins University, the Johns Hopkins Health System Corporation, or any of their constituent entities and a third party.
- Seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
- Services on advisory committees or review panels for a U.S. federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
- Intellectual property. A covered party's financial interests in intellectual property (e.g., patent applications, patents, copyrights) that is licensed to an outside entity or that is the subject of agreements involving potential income or other valuable consideration. This includes intellectual property that is licensed by the Johns Hopkins University, the covered party, or any other entity.
- Equity and other financial interests. Financial interests, such as investments, that reasonably appear to be related to a covered party's institutional responsibilities. This does not include income from investment vehicles, such as mutual funds and retirement accounts, if the covered party does not directly control investment decisions in these vehicles.
- Fiduciary and management roles in non-Hopkins entities. This includes but is not limited to service on boards of directors, or as an officer, manager, or medical director of a for-profit company or non-profit organization, including charitable foundations.
- Travel. Covered parties who are investigators on PHS-funded research projects or applications for PHS funding (5) must disclose each occurrence of reimbursed or sponsored travel related to a covered party’s institutional responsibilities if the value of the reimbursed or sponsored travel occuring during the 12 months prior to the disclosure, when aggregated for a particular entity, is $5,000 or more. This includes the value of sponsored or reimbursed travel for the covered party's spouse, domestic partner, and dependent children, if applicable.
Disclosure must include the purpose, sponsor/organizer, destination, and duration of each occurrence. Disclosures should specify the name of the entity to which the service was provided, not the name of an intermediary organization engaged to handle logistics or payment.
- This does not include travel paid for by Johns Hopkins University, the Johns Hopkins Health System Corporation, or any of their constituent entities, or travel that is sponsored or reimbursed by local, state, and federal government entities; institutions of higher education as defined at 20 U.S.C. 1001(a), academic teaching hospitals, medical centers, or teaching hospitals, medical centers, or research institutes affiliated with an institution of higher
- This does not include travel sponsored or reimbursed for the spouse, domestic partner, or dependent children if the spouse, domestic partner, or dependent child is employed by the entity or if the travel relates to the spouse, domestic partner, or dependent child's own employment responsibilities.
- Additional reporting for full-time and salaried part-time faculty:
- Additional information about outside activities and/or interests, including those listed above as exclusions, may be requested at any time by the department director or the Dean (6) in connection with any of the following: appointments, promotions, administrative assignments, performance reviews, requests for institutional clearance, certification of research, application for support of academic endeavors, purchases of equipment, relevant inquiries or investigators, or disciplinary reviews.
C. Disclosure Submission and Review Procedures
- Disclosure Submission:
- All reportable outside activities and interests (see “Activities and Interests to be Disclosed” section) must be disclosed. Disclosures must be made via the online disclosure system, eDisclose. Disclosures must be made prior to undertaking an outside activity and, where applicable, no later than the time of application for PHS funding and prior to expenditure of any project funds.
- Disclosures must be updated no later than 30 days from the date of acquiring or discovering a new financial interest or a change in a financial interest.
- Occurrences of travel must be disclosed within 30 days following the end of the travel, if the aggregate value of sponsored or reimbursed travel during the 12 months prior to disclosure is $5,000 or more.
- In addition to disclosing outside activities and interests, full-time and salaried part-time faculty must complete an annual certification to ensure that their disclosures are accurate and up-to-date.
- Disclosure Review:
- All disclosures will be reviewed by the division for compliance with this policy and applicable divisional policies.
- The outcome of the review will be communicated to the faculty member and the department director in writing. The activity or interest is not considered approved until this written approval has been sent to the faculty member.
- Disclosure information is available for review by department (and in some cases division) directors and administrators. Department directors may require that their faculty members obtain their review and approval prior to disclosing in eDisclose.
- Maintenance of Records:
- Disclosures will be maintained in the JHU online disclosure system for three years after project termination and close-out.
D. Determinations Regarding Outside Commitments
- Determining whether a particular outside activity or interest constitutes an acceptable or unacceptable time commitment is the responsibility of the faculty member’s department director, who may seek consultation with the divisional Dean's Office.
- Department directors may place restrictions on or deny any activity or interest if they believe the activity or interest is likely to negatively impact a faculty member’s ability to fulfill his or her University responsibilities due to the amount of time required by, or the nature of, the outside activity or interest. For such a determination to be made, directors may evaluate areas of faculty responsibility and productivity, including but not limited to their various forms of service (including clinical care for physicians), research, and teaching.
E. Review for Conflict of Interest
Review for conflict of interest with research is conducted in accordance with the University Policy on Individual Financial Interests and Conflicts of Interest in Research, as well as any additional Divisional policy.
F. Activities Subject to Additional Conditions or Limitations
a. Endorsement & Promotion
Any activity that could imply or constitute endorsement or promotion of any commercial product, technology, service, or company is prohibited.
b. Proprietary Information
Any private outside activity that involves the use of Johns Hopkins University proprietary information is prohibited. See http://jhuresearch.jhu.edu/JHU_Intellectual_Property_Policy.pdf.
c. Use of Name
Any outside activity that involves use of the names, logos, or brand marks of the Johns Hopkins University or its member organizations without explicit permission from the institution is prohibited.
d. Academic Freedom
Any activity that compromises the basic scholarly independence and freedom of action that are central to University life is prohibited. Activities that restrict or interfere with a faculty member's ability to conduct research and other academic activities such as publishing or presenting research results are prohibited. See http://jhuresearch.jhu.edu/Policy_onConflict_of_Interest.pdf.
e. JHU resources
Any substantive private activity conducted for a non-Johns Hopkins entity that involves the use of Johns Hopkins resources is prohibited unless there is explicit, documented approval by one's department director (or by the Dean, in the case of department directors). In general, an activity involving the use of University resources must be the subject of an institutional agreement. http://jhuresearch.jhu.edu/Policy_onConflict_of_Interest.pdf.
F. Time Limit
Engaging in an outside activity is considered a privilege. Outside activities should not distract faculty members from fulfilling their responsibilities, and devoting professional loyalty, time, and energy to their teaching, research, patient care and academic development. Therefore, the amount of time spent on outside commitments that are compatible with fulfilling one's responsibility to the University and one's appropriate academic pursuit needs to be determined by the department director after discussion with the faculty member.
G. Sanctions for Non-compliance
Violations of this Policy on Disclosure and Professional Commitment are subject to each JHU division's disciplinary procedures or procedures for dealing with issues of professional misconduct.
- Faculty members at other University divisions must comply with the JHU Policy on Conflict of Interest and Conflict of Commitment.
- Department directors’ activities are approved by the Dean or his/her designee. Throughout this policy, the term "department director" refers to heads of academic departments, e.g., department chairmen or department directors.
- The department director may appoint a designee, such as the faculty member’s division director, to review and monitor professional commitment. In the context of this policy, the term “Department Director” used hereinafter shall include his or her designee.
- For investigators at sub-recipient institutions, “related to one’s institutional responsibilities” means financial interests that are directly related to the work the investigator is doing for the prime awardee institution.
- An investigator is any individual who is responsible for the design, conduct, or reporting of the research. This includes: 1) Project director or principal investigator and any other person responsible for the design, conduct, or reporting of research. Includes collaborators and consultants. 2) All study team members on IRB applications. This definition is independent of whether one is appointed or employed by the Johns Hopkins University. The phrase "responsible for the design, conduct, or reporting of research" should be interpereted to mean any individual involved in the research who works independently enough to affect the objectivity of the design, collection, or analysis of research data or reporting of research results. In addition to faculty members, this may include graduate and post-doctoral trainees, research staff, consultants, or other collaborators. The ultimate determination as to who is considered an investigator in PHS-supported research is the decision of the PI of the project.
- A Dean may ask a designee, such as the Vice Dean for Research, to request such a report. In the context of this policy, the term “Dean” used hereinafter shall include his or her designee.