OHSU

OA Approving Instructions

General Instructions

Approving Authorities shall promptly review disclosure statements and determine whether or not to approve, with or without conditions, a request to engage in an outside activity. In addition, they determine what, if anything, needs to be done to avoid, dispose of, or manage a disclosed conflict, and also determine if acceptance of a gift under the disclosed circumstances is permissible. The Approving Authority will determine if the disclosed OA must be reviewed and approved by the Provost or Chief Administrative Officer. In determining the appropriateness of the outside activity, the Approving Authority shall evaluate:

  • Whether the OA is within the parameters of the Acceptability Criteria.
  • If an acceptable management plan may be instituted to monitor the employee's OA.
  • If there is to be no reduction in FTE and the anticipated time commitment is likely to interfere materially with the employee's duties to OHSU, any approval must include written documentation and substantiation by the Approving Authority that the OA shall yield extraordinary benefits to both OHSU and the requesting employee.

1. As needed, Approving Authorities may consult with others in employee's school/unit, the Legal Department, or the OHSU Integrity Office.

2. Approving Authorities shall be fair and impartial in their review of disclosure statements and shall not arbitrarily deny requests.

3. The Approving Authority shall promptly notify the employee of his or her decision regarding a disclosure statement, providing written documentation of any finding that served as grounds for denial.

4. If, for any reason, the Approving Authority is unable to conduct a fair and impartial review of a disclosure statement, the Approving Authority shall relinquish his or her responsibilities as Approving Authority to the employee's Dean or Director.

5. The Approving Authority may institute a reasonable compliance management plan (coordinated with any related Conflicts of Interest or Conflicts of Interest in Research plans) to monitor the employee's related OA, including, but not limited to, periodic review of related OAs. Approving Authorities may delegate responsibility for monitoring compliance with management plans. The management plan should be provided to the disclosing employee and documented by the department.

6.  Approval for an OA applies only to that OA and not to any modification or increase of the OA. It is the requesting employee's responsibility to apply or re-apply for approval of any modification of OA.

7.  Approval of any OA may be revoked or made contingent upon one or more conditions, at the Approving Authority's discretion.

8 . Approving Authorities may need to forward a copy of faculty members' disclosures along with the management plan to the dean or director (depending on school/unit internal policy).

9.  Approving Authorities may also need to forward a copy of a faculty member's disclosure to the Provost or a non-faculty employee's disclosure to the Chief Administrative Officer.

Chief Administrative Officer

Approving authorities must forward a copy of an employee's (other than faculty) CoI disclosure and its resolution to the Chief Administrative Officer if the CoI is in one or more of the following categories:

  1. Making referrals of OHSU business (verb) to an entity in which the employee, the employee's relative, or an entity associated with the employee or his/her relative has a significant financial interest.
  2. Loaning OHSU equipment to an entity.
  3. Involvement in the negotiation of a contract between OHSU and an entity with which the employee, the employee's relative, or an entity associated with the employee or his/her relative has a significant financial interest.
  4. Receiving compensation for OHSU activities that benefit an entity unless authorized by an appropriate agreement between OHSU and the entity.
  5. Transmitting without authorization and with expectation of personal financial gain, confidential and/or proprietary information, records, results, materials, or products that have been acquired through research or the use of resources at OHSU.
  6. Assuming an executive position in an entity engaged in potential or actual competition with OHSU interests or activities.
  7. Unauthorized use of privileged information acquired in connection with the employee's OHSU responsibilities.
  8. Using one's OHSU role or position to solicit a charitable gift or contribution from an OHSU vendor or other entity with a business relationship with OHSU for the benefit of a non-OHSU charity, not-for-profit organization, business, or other entity.
  9. Using one's OHSU role or position to solicit a charitable gift or contribution from any entity for the benefit of a non-OHSU health and science-related charity, not-for-profit organization, business, or other entity that competes with OHSU.

Provost

Approving authorities must forward a copy of a faculty member's CoI disclosure and its resolution to the Provost if the CoI is in one or more of the following categories:

  1. Receipt of OHSU-supervised support (whether in dollars or in kind) from a business with which the employee or his/her relative has a significant financial interest.
  2. Assuming a board position, directorship, or executive position for an entity engaged in biomedical research, health care, or health-related education.
  3. Making referrals of OHSU business (verb) to an entity in which the employee, the employee's relative, or an entity associated with the employee or his/her relative has a significant financial interest.
  4. Loaning OHSU equipment to an entity.
  5. Service on a board of directors or scientific advisory board of, or any executive position with, an entity from which the employee, employee's relative, or an entity associated with the employee or his/her relative receives OHSU-sponsored support.
  6. Involvement in the negotiation of a contract between OHSU and an entity with which the employee, the employee's relative, or an entity associated with the employee or his/her relative has a significant financial interest.
  7. Privately pursuing patents and licensing agreements in which OHSU might have a legitimate interest.
  8. Receiving compensation for OHSU activities that benefit an entity unless authorized by an appropriate agreement between OHSU and the entity.
  9. Receiving funds, gifts, or any compensation from an entity that is sponsoring an employee's OHSU activities, for activities or purposes unrelated to the costs of performing the sponsored OHSU activities.
  10. Transmitting without authorization and with expectation of personal financial gain, confidential and/or proprietary information, records, results, materials, or products that have been acquired through research or the use of resources at OHSU.
  11. Assuming an executive position in an entity engaged in potential or actual competition with OHSU interests or activities.
  12. Assigning to fellows and/or students, tasks related to an employee's involvement with an entity.
  13. Speaking, acting, or writing that creates the impression that an employee speaks for OHSU, unless authorized to do so.
  14. Associating an employee's name or work with OHSU in such a way as to profit monetarily by trading on the reputation of OHSU rather than on the employee's own competence.
  15. Unauthorized use of privileged information acquired in connection with the employee's OHSU responsibilities.
  16. Using one's OHSU role or position to solicit a charitable gift or contribution from an OHSU vendor or other entity with a business relationship with OHSU for the benefit of a non-OHSU charity, not-for-profit organization, business, or other entity.
  17. Using one's OHSU role or position to solicit a charitable gift or contribution from any entity for the benefit of a non-OHSU health and science-related charity, not-for-profit organization, business, or other entity that competes with OHSU.