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Policy on Disclosure and Professional Commitment

The Policy on Disclosure and Professional Commitment contains the following sections: 

  1. Introduction
  2. Activities and Interests to be Disclosed
  3. Disclosure Submission and Review Procedures
  4. Determinations Regarding Outside Commitments
  5. Review for Conflict of Interest
  6. Activities Subject to Additional Conditions or Limitations
  7. Time Limit
  8. Sanctions for Non-compliance

The Policy on Disclosure and Professional Commitment was adopted by the Advisory Board of the Medical Faculty on May 16, 2012, and additional revisions were adopted on November 14, 2012.  For a printable version of this Policy, click here.

A.    Introduction

As part of a University devoted to the development and advancement of science and medicine, faculty members and other investigators engage with industry, government, and professional associations 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:

  1. Each member of the faculty of the Johns Hopkins School of Medicine 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 designee and fully report the activity to the university.  (1)

  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, patient care, and administrative responsibilities at the School of Medicine.

  3. This policy applies to all full-time and salaried part-time faculty members in The Johns Hopkins University School of Medicine and other individuals as defined in section A.4. below.   Individuals governed by this policy are referred to as “covered parties.”

    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 School. 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, patient care, 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.  (2)

Non-salaried part-time faculty should refer to the Blue Book for applicable policies.

  1. Other individuals may be governed by this policy in full or in part pursuant to contractual arrangements between the Johns Hopkins University School of Medicine and other entities.   This includes investigators on sub-awards from Johns Hopkins, with modifications specified below.

  2. Disclosures made pursuant to this policy will be reviewed, as appropriate, for conflicts of interest with research.  These reviews will be governed by School and University policies on conflict of interest and financial interests in research.  

  3. Disclosures made pursuant to this policy will be reviewed, as appropriate, for compliance with other institutional policies such as, for example, the JHM Policy on Interaction with Industry. 

B.    Activities and Interests to be Disclosed

  1.  A covered party must disclose any of the following time commitments and/or financial interests that reasonably appear to be related to his/her institutional responsibilities:

    1. Services to outside entities, including any income or remuneration in any form that will be received, that may be reasonably related to one's institutional responsibilities.  (3Institutional responsibilities are those activities for which one is employed or appointed by the School of Medicine.  Examples may include but are not limited to research, teaching/education, clinical practice, and administrative responsibilities.

      1. This includes, but is not limited to:  consulting, scientific advisory board service, honoraria for lecturing, and compensated medical-legal ("expert witness") consulting and testimony.
      2. 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.
      3. Services to U.S. government agencies, other than those services listed below as exclusions, must be reported.
      4. 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.
      5. 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.
      6. This does not include:
        1. Services to the Johns Hopkins University, the Johns Hopkins Health System Corporation, or any of their constituent entities.
        2. 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.
        3. 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.
        4. 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.
        5. Services provided by spouses, domestic partners, and dependent children without income or remuneration.
    2. 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.
    3. 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.
    4. 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.
    5. Travel.  Covered parties who are investigators on PHS-funded research projects or applications for PHS funding (4) 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 occurring 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.
      1. 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 U.S. local, state, and federal government entities; U.S. institutions of higher education as defined at 20 U.S.C. 1001(a); U.S. academic teaching hospitals, medical centers; or U.S. teaching hospitals, medical centers, or research institutes affiliated with a U.S.  institution of higher education.
      2. 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.
  2. Additional reporting for full-time and salaried part-time faculty:
    1. 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 (5) 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.

For additional information, contact the Office of Policy Coordination (OPC).

C.    Disclosure Submission and Review Procedures

  1. Disclosure Submission:
    1. All reportable outside activities and interests (see “Activities and Interests to be Disclosed” section) must be disclosed via the online disclosure system, eDisclose. Disclosures must be made prior to undertaking an outside activity.
    2. 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.
    3. 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.
    4. 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.
  2. Disclosure Review:
    1. All disclosures will be reviewed by OPC for compliance with this policy, the University Policy on Individual Financial Interests and Conflict of Interest in Research, and other applicable policies.
    2. The outcome of the review will be communicated to the faculty member and the Department Director in writing via eDisclose. Disclosures are not considered approved until approval has been sent to the faculty member by OPC. Approvals may be subject to conditions.
    3. 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. Department directors may re-evaluate their approval at any time.

D.    Determinations Regarding Outside Commitments

  1. 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 OPC.
  2. 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 clinical service, 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.

F.    Activities Subject to Additional Conditions or Limitations

Regulated Activities include but are not limited to:

  1. Patient Care Outside the Johns Hopkins University and Johns Hopkins Health System
    Note:  This section applies to full-time faculty only.
    1. Faculty members may not provide patient care at a facility or practice other than a Johns Hopkins facility or practice unless the patient care services are the subject of a contract between Johns Hopkins and the outside facility or practice. All fees or other remuneration for patient care services of faculty, and the right to bill and collect such fees or other remuneration, belong exclusively to Johns Hopkins University, and faculty are not permitted to bill, collect or retain any fees for patient care services they provide, regardless of where or when such services are performed.

      Contracts to provide patient care outside a Johns Hopkins facility or practice and within the United States are exclusively administered by the School of Medicine Clinical Practice Association. Contracts to provide patient care outside a Johns Hopkins facility or practice and outside the United States are exclusively administered by Johns Hopkins Medicine International, LLC.

    2. Exceptions:
      1. If a faculty member proposes to provide patient care services at a non-Johns Hopkins facility or practice in the United States absent a contract between Johns Hopkins and the outside facility or practice, s/he must request and receive approval from his/her department director and the Vice Dean for Clinical Affairs prior to initiating the service and must confirm that there is appropriate malpractice insurance coverage. Failure to obtain approval may result in action to collect any fees or other remuneration received by the faculty member for such services and a denial of insurance coverage for any claims resulting from such services.
      2. If a faculty member proposes to provide patient care services at a non-Johns Hopkins facility or practice outside the United States absent a contract with Johns Hopkins Medicine International, LLC, s/he must request and receive approval from his/her department director and the Vice Dean for Clinical Affairs prior to initiating the service and confirm that there is appropriate malpractice insurance coverage.  Upon return to the United States, the faculty member must report to the department director and Johns Hopkins Medicine International all amounts received for the provision of patient care, including amounts received as fees or other remuneration for patient care services and gratuities and turn over to the department all such amounts received for handling in accordance with university, School of Medicine and department procedures.  Failure to obtain approval; to make the required report; or to turn over funds or other property received may result in action to collect any fees, other remuneration, or gratuities received by the faculty member for such services and a denial of insurance coverage for any claims resulting from such services.
  2. Speaking for Industry

Service as a speaker for industry is prohibited if the arrangement has any of the characteristics listed below.  Training others to engage in a speaking activity that has any of these characteristics also is prohibited.

  • the company has the contractual right to dictate or control the content of your presentation or talk
  • the company creates the slides or presentation material and has final approval of the content and edits
  • the speaker is expected to act as a company’s agent or spokesperson for the purpose of disseminating company-generated presentation materials or promoting company products.

See the Policy on Speaking for Industry and the Policy on Interaction with Industry.

     3.     Other

a. Endorsement & Promotion

Any activity that could imply or constitute endorsement or promotion of any commercial product, technology, service, or company is prohibited.  See http://brand.hopkinsmedicine.org/gui/content.asp.

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, Johns Hopkins Medicine, or its member organizations without explicit permission from the institution is prohibited.  See http://brand.hopkinsmedicine.org/gui/content.asp.   

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.

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.
 

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 Professional Commitment policy are subject to the School of Medicine's Procedures for Dealing with Issues of Professional Misconduct.  

Footnotes

  1. Department directors’ activities are approved by the Dean or his/her designee.
  2. 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.
  3. 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.
  4. An investigator is any individual who is responsible for the design, conduct, or reporting of research.  This includes:
    • Project director or principal investigator and any other person responsible for the design, conduct, or reporting of research.  Includes collaborators and consultants.
    • 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 interpreted 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.
  5. The 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.
 

MSCHE: Self-Study Report for the School of Medicine

The School of Medicine has completed its Self-Study for the Middle States Commission on Higher Education accreditation review. Please review the self-study here.

 

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