Frequently Asked Questions
What information do I need to provide when I make a disclosure?
- The name of the entity for which you provide a service or in which you have a financial interest
- A description of the nature of the service or interest
- The form and amount of remuneration
- Details regarding the time commitment involved, if any
- Information regarding related research
- Information regarding related purchasing responsibility
What happens to my disclosure?
- Divisional staff will review your disclosure.
- In most cases, staff will assign relevant administrative conditions to the disclosure (e.g., guidelines for consulting with outside entities or for speaking engagements).
- Some financial interests create conflicts of interest with research. In many cases, staff will assign conditions to address risks associated with the financial interests. The conditions may include changes to a research project. For example, the individual with the financial interest may be prohibited from soliciting consent from prospective research subjects. Disclosure to appropriate audiences (e.g., journals, scientific meetings, lab members, collaborators) will almost always be required.
- Some disclosures will be referred to the division’s conflict of interest committee (e.g., for the School of Medicine, the Committee on Outside Interests) for review.
- If a financial interest associated with PHS-supported research is determined to be a financial conflict of interest under regulatory standards, details of the arrangement will be reported to the awarding agency and certain information about the arrangements must be made available to the public.
- For more specific information about your division’s review process, please click here.
Do I need to get departmental or divisional approval before I disclose consulting or other outside services?
Generally not, although your department or division may require that you disclose your outside activities and time commitments to the unit before disclosing in eDisclose. If your school or division’s reviewing office decides that director or chair approval is required for a particular arrangement, your review will not be processed until that approval is received. Department directors and chairs are able to view all of their faculty members’ disclosures in eDisclose. They have the authority to limit outside activities if they believe the activities interfere with a faculty member’s ability to fulfill his or her Johns Hopkins duties.
How is information regarding a faculty member’s outside activities and/or financial interests conveyed to his/her department director or chair? What information is provided?
Department and division directors and chairs have access to eDisclose so they can review the disclosures of faculty members in their department or division.
If I am on sabbatical, do I need to submit disclosures?
What if I write a book chapter and, although I do not receive any income, the publisher gives me a copy of the book? Should I disclose receipt of the book?
The receipt of the book does not need to be disclosed.
I receive royalties from sales of an academic textbook. Do I need to disclose this?
Yes. Pursuant to revised federal regulations on conflict of interest and institutional policy, income received from publishing, editing, or authoring must be disclosed.
I’m involved in research using licensed intellectual property for which I’m entitled to royalties, although there are no royalties flowing yet. Do I need to disclose this since I haven’t received any income from royalties?
Yes. Entitlement to future royalties under a licensing agreement or contract is a disclosable financial interest.
What if Johns Hopkins owns equity in the start-up company in which I have equity or a licensing interest?
You still need to disclose your equity and licensing interests in the company for review under the policy on individual conflict of interest. The university’s ownership interest in the start-up can create an institutional conflict of interest, which is reviewed under the University’s policy on institutional conflict of interest.
How do I determine whether a company in which I own stock is related to my institutional responsibilities?
Institutional responsibilities are those responsibilities and roles that covered parties are assigned in the course of their appointment or employment at the university. This includes, for example, clinical practice, teaching, research, research consultation, professional practice, administrative roles, committee service, purchasing-related responsibilities, and service on IRBs or DSMBs. Ownership of equity in an entity whose business is in the same field as any of your institutional responsibilities is considered related. For example, if you are a consultant to a pharmaceutical company because they are considering developing a drug for a disease you treat in your clinical practice, that must be disclosed whether or not you conduct research related to the drug, the disease, or the company.
Do I need to disclose if I am advising Johns Hopkins students who started a company based on the technology they invented at the university?
If you are advising the students in their roles as company founders, you are engaging in an activity with an outside organization and you need to make a disclosure. This is especially important if you are compensated in any way. If you are mentoring the students with regard to their university-based research activity, no disclosure is needed.
Can you provide some examples of when to disclose the financial interest of a spouse/domestic partner/dependent child?
- ownership of stock in an entity that relates to your institutional responsibilities; and
- service on the board of directors of an entity that relates to your institutional responsibilities; and
- receipt of remuneration for consulting or any other service provided to an entity that relates to your institutional responsibilities.
My spouse works for a company that is related to my institutional responsibilities and I am required to disclose his income and stock options to JHU. However, his employer imposes confidentiality requirements on disclosure of his compensation.
To comply with institutional policy and federal regulation, limited information about interests of immediate family members must be disclosed. If you have questions about a particular case, please contact your school or division’s reviewing office.
If both members of a married couple or domestic partnership are faculty and/or investigators at Johns Hopkins, do they need to disclose each other’s interests or activities?
Yes. Although each member of the couple has certain disclosure requirements, it is important for each to include the other’s disclosable financial interests and indicate they are the spouse or domestic partner’s interests. This is so the institution can determine whether an individual’s financial interests are related to the research being conducted by the other member of the couple.
Do I need to disclose if my spouse is employed by NIH?
Do I need to disclose my spouse’s employment for a company whose business is related to my institutional responsibilities?
Do I need to disclose if my spouse is a lobbyist for a company whose business is related to my institutional responsibilities (e.g., for SOM, a pharmaceutical company)?
Common Examples for What to Disclose
Below are examples of typical arrangements and/or financial interests:
|Nature of Arrangement
|Consulting for a for-profit company with any fee
|Consulting fee from the Gates Foundation
|Consulting for Baltimore City Department of Public Health
|Service on Advisory Board
|Service on FDA advisory panel
|Service on FDA advisory panel with honorarium paid for by a third-party contractor
|Advisory service to government of China
|Honorarium for lecture at University of Michigan
|Honorarium for lecture at the University of Oxford
|Hotel in Chicago paid for by the American Heart Association
|Travel paid for by industry (directly to the individual, not via Johns Hopkins)
|Travel paid for by the Gates Foundation
|Travel to University of Michigan paid for by the University of Michigan
|Travel to the University of Oxford paid for by University of Oxford to give lecture
|Travel to Chicago paid for by American Heart Association
|Travel to a research meeting in California paid for with JHU department funds
|Merck stock inherited by spouse
|Equity in startup company
|Ownership of mutual fund
|Inventor of technology for which a patent application was filed but is not licensed
|Inventor of licensed technology
|Inventor of technology given or assigned to a company or other organization for commercialization