OHSU

Acceptability Criteria

Acceptability criteria are guidelines for types of relationships or arrangements that could indicate a potential conflict of interest. Engaging in an activity that is included on the list does not automatically mean that a conflict of interest or other prohibited relationship exists; it does mean that the activity or relationship needs to be disclosed, discussed, and, if appropriate, managed.

 

An outside activity may be considered to be unacceptable if:

  • It compromises the ability of OHSU to achieve its missions
  • It compromises the ability of any employee to fulfill the academic, professional, or institutional responsibilities for which OHSU employs him or her
  • It damages the reputation or compromises the integrity of OHSU or any of its employees
  • It alone or through cumulative effect, materially interferes with the employee's ability to fulfill assigned duties to OHSU by:
  • Requiring a substantial time commitment that materially detracts from the employee's assigned work
  • Negatively impacting the needs of the employee's assigned unit or department
  • Detracting from the time allocation required by the employee's current FTE status
  • It has a negative impact on students or interferes with the employee's instructional, research, or other related institutional responsibilities
  • It uses OHSU facilities, support personnel, or other resources
  • It creates a conflict of interest such as:
  • Placing OHSU business with any person or company in which the employee or the employee's relative has a direct or indirect interest
  • Hiring or supervising a relative or domestic partner
  • Teaching, conducting research, or providing patient care at another education or health care institution by any disclosing employee as defined in policy 10-01-015 without prior written approval from an authorized OHSU official
  • Accepting a gift in violation of the Gifts to Individuals policy
  • Diverting research, research grant applications, education activities, or patient care (where not medically indicated) away from OHSU to other persons or organizations
  • Accepting or arranging a charitable gift or contribution to OHSU, OHSU Foundation, or Doernbecher Foundation in return for a business relationship with OHSU
  • Endorsing a vendor's products or services on behalf of OHSU without obtaining prior approval
  • Privately pursuing patents, licensing agreements, copyrights, or trademarks for intellectual property in which OHSU might have a legitimate interest
  • Transmitting or agreeing to transmit or use, without prior authorization, confidential, privileged, or proprietary information, records, results, materials, or products that have been acquired through research, clinical, or academic activity or the use of OHSU resources
  • Service on a board of directors or scientific advisory board or acting in any management capacity for a private enterprise from which the employee, employee's relative, or an entity associated with the employee or the employee's relative, receives support for any OHSU activity
  • Involvement in the negotiation of contracts between OHSU and outside organizations in which the employee, the employee's relative, or an entity associated with the employee has any compensation arrangement, economic or ownership interest
  • 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.
  • 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.

 

Additional Note for Clinicians

Physician-industry collaboration can produce important benefits for science and for patient care.  However, the goals of physicians and academic institutions and those of pharmaceutical and device manufacturers differ in some respects, creating the potential for conflicts of interest. 

 In some cases, payments to physicians by such companies go beyond what is justified for educational, scientific, or consulting services, and so may appear to influence their behavior to increase use of specific products.

Relations which are not based on appropriate services are inappropriate and may sometimes be illegal.  Appropriate management of potential conflicts of interest is therefore an important part of professional medical practice.