Guidelines for Disclosing
Krieger School of Arts and Science and Whiting School of Engineering Faculty
Login to eDisclose using your JHED ID and password: http://edisclose.jhu.edu.
- All full-time faculty and salaried part-time faculty are required to disclose outside activities and financial interests whether or not they participate in research.
- Non-salaried part-time faculty must disclose outside activities and financial interests if they participate in research.
- Other individuals involved in research at Johns Hopkins who meet the definition of “investigator” must disclose outside activities and financial interests. Under JHU’s conflict of interest policy, an investigator is:
- The 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.
Institutional policy and federal regulation mandate disclosure requirements to enable review for conflict of interest and professional commitment.
- Prior to undertaking an outside commitment
- Prior to submission of an application for PHS-funded research on which you are an investigator
- Within 30 days of acquiring or discovering a financial interest related to your institutional responsibilities
- Whenever a disclosed interest or activity changes (e.g., the amount or type of remuneration, type of service, or time commitment) or ends
- During the Annual Certification period (to ensure that disclosures are accurate and up-to-date)
In addition, all full-time and salaried part-time faculty are required to complete an Annual Certification.
Late disclosure and failure to disclose may have serious consequences. Under federal conflict of interest regulation, if there is a failure to disclose, belated disclosure, or belated review of financial interests that the institution determines create financial conflicts of interest with PHS-supported research, the institution must undertake a retrospective review of the completed research for bias. In addition, under School policies, failure to comply with policies on conflict of interest and commitment may lead to review under professional misconduct procedures.
The purpose of the Annual Certification is certifying via a series of questions which confirm disclosures of outside activities and financial interests submitted by full-time and salaried part-time faculty are accurate and up-to-date. This is a separate activity from submitting disclosures. Faculty members will be notified via email when their Annual Certifications are due, which is typically in the month of February. At that point the Annual Certification button appear in your dashboard of eDisclose. Those included in Annual Certification are:
- Full‐time faculty and salaried part‐time faculty must submit an Annual Certification, with the following titles:
- Professor/Associate Professor/Assistant Professor/Instructor
- Research Professor/Associate Research Professor/Assistant Research Professor
- Principal Research/Research/Associate Research/Assistant Research
- Visiting Professor/Associate Professor/Assistant Professor
- Visiting Research Professor/Associate Research Professor/Assistant Research Professor
- ONLY IF FULL‐TIME:
- Senior Lecturer/Lecturer/Junior Lecturer
- Teaching Professor/Associate Teaching Professor
- IF PARTICIPATING IN ANY RESEARCH:
- Adjunct Professor/Adjunct Associate Professor/Adjunct Assistant Professor
You must disclose using JHU eDisclose, the University’s online disclosure system. The system is accessible anytime and anywhere there is a working internet connection. You will need your JHED ID and password to enter the system. If you are not able to access eDisclose, please contact Laura Evans, Executive Director, to request an account.
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You must disclose the outside activities and financial interest listed below if they are related to your “institutional responsibilities.” Institutional responsibilities may include, among other things, research, teaching, clinical care/practice, and administrative responsibilities. Disclosure is required so the School can review outside interests and activities for conflict of interest and conflict of commitment.
Activities – whether or not compensated (with the exception of publishing/editing/authoring):
- Service on advisory board, committees or review panels*
- Publishing/editing/authoring (if remuneration is anticipated)
- Board of Directors
- Medical-legal activity
- Speaking, teaching and lecturing*
*Exceptions. The following outside activities do not need to be disclosed if they are provided to a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute:
- Scientific advisory board, committee, or review panel
- Speaking, teaching, and lecturing
- Inventor of licensed technology
- Receipt of income from licenses, whether equity, royalty, or other
- When the technology is licensed by JHU, disclose royalty distributions only when the annual amount received from a single licensee exceeds $5,000 (Note: Full-time and salaried part-time faculty will receive a report that includes this data during annual certification.)
- Entitlement to equity and/or royalty
- Equity ownership (except mutual funds)
You must disclose any of the above outside activities or financial interests of your spouse, domestic partner and/or minor dependents if they relate to your institutional responsibilities.
Reimbursed or Sponsored Travel:
If you are an investigator on PHS-funded research, you must disclose occurrences of reimbursed or sponsored travel related to your institutional responsibilities when the amount of travel during the 12 months preceding the disclosure reaches or exceeds $5,000 in the aggregate for a particular entity. (Note: This aggregate value includes travel for spouses, domestic partners and dependent children unless the travel occurs in the course of their employment by the entity.) This does not include travel that is reimbursed or sponsored by a U.S. federal, state, or local government agency, teaching hospital, medical center, U.S. institution of higher education, or related research institute. Exceptions also include travel reimbursements to Johns Hopkins, travel payments made by Johns Hopkins, or travel charged to a Johns Hopkins account.
Is there anything I shouldn’t disclose?
- The exceptions listed above
- Activities that are governed by an institutional agreement or contract between Johns Hopkins and a third party
- Payments from Johns Hopkins (e.g., salary, salary supplement, reimbursements), other than payments derived from institutional licenses of intellectual property
- Confidentiality agreements with no services or remuneration
- Participation in local community activities (including, but not limited to, religious institutions, schools, clubs, and local charities outside the biomedical field), unless (i) you conduct research that relates to the organization, or (ii) the organization has a relationship with Johns Hopkins or seeks to do business with Johns Hopkins and you have any role in that relationship or business.
Please click here to review some common examples of outside activities and financial interests, along with guidance on whether or not each item must be disclosed.
If your disclosed relationship with an entity changes in any way, you need to update your disclosure. Updates should be submitted in eDisclose.
- Your relationship with the company/entity has ended
- Your service has changed (e.g., type of service provided, time commitment, amount or type of remuneration)
- You propose to participate in research related to the entity (a new protocol or a new research grant or contract)
- Your intellectual property is licensed to the entity
Disclosures are reviewed for conflict of interest and, for full-time and salaried part-time faculty, conflict of commitment. You will be contacted via e-mail or telephone if additional information is needed. Every effort is made to review disclosures in a timely way. Timing of review depends on a number of factors, including, but not limited to, review by the Conflict Review Committee and submission during high-volume periods. If you need immediate review of a disclosure, please contact Laura Evans, Senior Policy Associate.
When the review of a disclosure is completed, the discloser will receive an e-mail notification that the review outcome is available in their eDisclose account.
Outcomes and decisions can be appealed by rejecting the electronic management plan that is sent via eDisclose. Appeals must be submitted within 30 days of receipt of an outcome. Appeals should be accompanied by an explanation of the reason for the appeal. You may be asked to submit more material and/or meet with the Committee.