Guidelines for Disclosing

School of Advanced International Studies Faculty

Who needs to disclose?

Covered individuals: This includes University Officers, faculty, staff and others who:
• Are compensated or otherwise supported by the university for their services.
• Use, control, or assign to others the use of university facilities and resources.
• Participate or engage in University Research.
• Teach at the University. Students and part-time faculty are considered “Covered Individuals” when they meet any of the categories mentioned in this category. 

Why do I need to disclose my outside interests and activities?

Institutional policy and federal regulation mandate disclosure requirements to enable review for conflict of interest and professional commitment.

When do I disclose?

Covered Individuals must timely disclose all financial interests and outside activities in writing or through an established electronic disclosure system as specified by SAIS or divisional policy or procedure. Disclosures must be made:

• Before a covered individual engages in an outside activity or acquires a financial interest.
• When a previously disclosed financial interest or outside activity changes or ends.
• At the time a covered individual applies for funding from a Public Health Service agency.
• Within 30 days of reimbursed or sponsored travel related to a covered individual’s institutional responsibilities, for all covered individuals who are investigators on Public Health Service funded research if the value of the covered individual’s (including his/her spouse, domestic partner and dependent children) reimbursed travel from any third party exceeds $5,000.00 in the previous months.

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 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. 

What is Annual Certification?

The purpose of the Annual Certification is to confirm disclosures of outside activities and financial interests submitted by full-time and salaried part-time faculty are accurate and up to date. These faculty members will be notified via email when their Annual Certifications are due, which is typically the first quarter of the calendar year.

Full‐time faculty and salaried part‐time faculty must submit an Annual Certification, including those in the following categories:
• Professor (tenured and non-tenured)/Associate Professor (tenured and non-tenured)/Assistant Professor/Associate Professor of the Practice/ Professor of the Practice Instructor/ Eni Professor
• Resident Professor/ Research Professor/Associate Research Professor/Assistant Research Professor
• Scholar
• Principal Research/Research Associate/Research Fellows/Associate Practitioner in Residence/ Practitioner in Residence/Assistant Research
• Visiting Professor/ Visiting Scholar/Associate Professor/Assistant Professor
• Visiting Research Professor/Associate Research Professor/Assistant Research Professor

Only in Fill-Time:
• Senior Lecturer/ Senior Fellow/Senior Research Professor/Lecturer/Junior Lecturer/Coordinator/Assoc Lecturer/Director/ Distinguished Practitioner-in-Residence/Professorial Lecturer/Professor Emeritus
• Teaching Professor/Associate Teaching Professor

If Participating in any research:
• Adjunct Professor/Adjunct Associate Professor/Adjunct Assistant Professor/Senior Adjunct Professor/ Adjunct Lecturer/Post-Doctoral Fellow/Pre-Doctoral Fellow 

How do I disclose?

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 Ogechi Abeduo Contracts and Grants Analyst to request an account.

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What do I need to disclose?

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 and administrative responsibilities. Disclosure is required to review outside interests and activities for conflict of interest and conflict of commitment.

Activities – whether compensated or not:
• Service on advisory committees or boards and review panels, except when provided to a U.S. state, federal or local government agency or institution of higher education or related research institute.
• Publishing/editing/authoring (if remuneration is anticipated)
• Board of Directors
• Founder
• Officer
• Manager
• Speaking, teaching and lecturing, except when provided to a U.S. state, federal or local government agency or institution of higher education or related research institute.

Financial Interests:
• Inventor of licensed technology and Publishing
• Receipt of income from licenses, whether equity, royalty, or other
• 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.

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. 

How do I update my disclosure?

If your disclosed relationship with an entity changes in any way, you need to update your disclosure. Updates should be submitted in eDisclose.

For example:
• 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.

For assistance updating your disclosure, refer to the eDisclose User Guide: How to Update a Disclosure or contact Ogechi Abeduo Contracts and Grants Analyst. 

What happens to my disclosure?

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 if additional information is needed. Every effort is made to review disclosures in a timely way. Timing of review depends on several 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 Ogechi Abeduo Contracts and Grants Analyst.

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. 

Can I appeal the outcome of a review?

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. If no response is received within 30 days, it is assumed that the outcome has been accepted by the discloser.

Where can I find the JHU policy?

SAIS faculty click here.