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Disclosing Personal Gifts Frequently Asked Questions

As stated in the Code of Professional Conduct for Faculty, “Faculty must refrain from accepting personal gifts without disclosure when the gift is directly or indirectly related to activity performed in one’s capacity as a faculty member.”  Questions about this policy are answered below:

1.

What is meant by “personal gifts”?

A personal gift is defined as any gift given to faculty which is directly or indirectly related to activities performed in her/his capacity as faculty.  Examples include Rolex watches, automobiles, and stays in luxury resorts.  While it may be given with the best of intentions, a personal gift valued in excess of $2500 may imply an expectation of special access to medical care.

The following are NOT considered gifts:  remuneration from consulting activities, honorariums for academic presentations, monetary rewards for scholarly prizes, and expert witness testimony.  These are considered outside activities and must be disclosed in eOPC and, if appropriate, managed by the Committee on Outside Interests.  See polices on Conflict of Interest and Professional Commitment for further information: http://www.hopkinsmedicine.org/som/faculty/policies/facultypolicies/conflict_interest.html  http://www.hopkinsmedicine.org/som/faculty/policies/facultypolicies/conflict_commitment.html.

Certain gifts and entertainment are covered by other University policies.  For example, gifts to individuals from industry are governed by The Johns Hopkins Medicine Policy on Interaction with Industry; gifts from vendors are governed by the University’s Statement of Ethical Standards and its Purchasing policies.


2.

How do I know if I need to disclose a gift?

Not all gifts need to be disclosed.  Only full-time and part-time faculty members are required to disclose gifts under the Code of Professional Conduct for Faculty.  You only need to disclose gifts valued at more than $2500.  You do not need to disclose a gift unless you have accepted it.  You do not need to disclose gifts that you receive outside of the context of your role as a faculty member, such as birthday or anniversary gifts, etc. from a family member or friend.


3.

How should I disclose a gift of more than $2500?

Disclose gifts using eDisclose, the University’s online disclosure system for conflict of interest.
  • Login to eDisclose with your JHED ID and password. 
  • Click on the green button marked “New Gift Disclosure”, located on the left side of your screen.
  • Complete the online form and click Finish.
  • Click the green arrow or “Submit” to complete your disclosure.
  • You, your department director (or designee), and the SOM Business office will receive an email with your gift disclosure details.

4.

How do I know if a gift (besides cash) is valued at over $2500?

Travel and Entertainment
In some cases, faculty members have personal relationships with patients and others with whom they also have a professional relationship.  Travel and entertainment (e.g., use of a home, boat, airplane, event tickets, entertainment) received from such an individual are not considered gifts under this policy IF the travel or entertainment are actively shared with the person(s) who give(s) the travel or entertainment.

If the travel or entertainment is not actively shared with the person(s) who give(s) the travel or entertainment (e.g., use of a home, boat, airplane, event tickets, entertainment), it will be considered a gift for purposes of this policy.  The value of these gifts is placed at $500/day, regardless of the market value of the gift.  Such a gift worth over $2500 (e.g., 10 days at a vacation home) must be reported as described above.

Gifts in kind
Gifts in kind (e.g., watch, art object) will be valued using the manufacturer’s suggested retail price (MSRP) if applicable.  If MSRP is not applicable, the faculty member is responsible for determining or estimating a fair market value of the gift.   If the value of a gift in kind exceeds $2500, it must be reported as described above.


5.

I accepted a gift valued at over $2500 and disclosed it.  Now what?

Faculty members must disclose gifts (description, total value, donor name, and date received) electronically via eDisclose, using the “New Gift Disclosure” button and completing the gift disclosure form.  Email notifications of submitted disclosures will be sent to the department director (and/or designee such as deputy department director or division director), department administrator, and SOM business office.  Faculty may keep $2500 (the allowed amount) of the gift (and are responsible for personal income tax for this amount), but must remit any funds above $2500 to the department administrator.

The department will pay institutional tax to SOM Business Office.

Departments will follow previously adopted policy, which will be provided to and applied uniformly to all faculty in the department, to govern distribution of the remainder of funds.

 

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