Disclosure Requirements

Login to eDisclose using your JHED ID and password: http://edisclose.jhu.edu.

Who needs to disclose?

• 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.

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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.

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When do I disclose?

• 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

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 of Medicine policy, failure to comply with policies on conflict of interest and commitment may lead to review under professional misconduct procedures. 

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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 the Office of Policy Coordination at [email protected] or call (410) 361-8667 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, 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:

• Service on advisory committees or boards and review panels, except when provided to a U.S. state, federal or local government agency, teaching hospital, medical center or institution of higher education or related research institute
• Publishing/editing/authoring (if remuneration is anticipated)
• Board of Directors
• Founder
• Officer
• Manager
• Medical-legal activity
• Speaking, teaching and lecturing, except when provided to a U.S. state, federal or local government agency, teaching hospital, medical center or institution of higher education or related research institute

Financial Interests:

• 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)
• Founder of Start-up

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.

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. 

Founder of Start-up:

• Guidance for Inventors whose Intellectual Property (IP) is Licensed to Startups

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.

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How do I update a 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 the Office of Policy Coordination at [email protected] or call (410) 361-8667. 

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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 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 Committee on Outside Interests and submission during high-volume periods. If you need immediate review of a disclosure, please contact the Office of Policy Coordination at [email protected] or call (410) 361-8667 . 

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.

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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.

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For additional information, please click here for FAQs and additional guidance.