OHSU

Outside Activities

Outside Activity (OA) - FAQ

What is an OA?

An activity is considered an "outside" activity when it is "outside" of the scope of the individual's employment with OHSU. An activity shall be considered a "related outside activity" requiring disclosure and approval when the activity:
  • Requires the employee to use the same academic, professional or institutional expertise for which he or she is employed by OHSU; or
  • Is conducted at OHSU owned or controlled premises, or uses OHSU facilities or support contrary to OHSU policies.
 

What has changed with the OA disclosure requirements?

Certain types of OAs only need to be disclosed retroactively as described in Section 4 of the policy. Examples include:
  • Receipt of royalties for published scholarly work
  • Occasional lecture participation with receipt of modest honoraria and expenses*
  • Occasional expert witness testimony not on a contract basis
These activities may be disclosed retroactively on an annual basis.  An estimate of the continuation and frequency of those activities for the next 12 months should be provided.
*Note additional requirements for OHSU employees participating in industry sponsored or industry subsidized lectures described on the Gifts page and FAQs
 
Other OAs must be disclosed and approved in advance.  Examples include:
  • Consulting agreements and scientific advisory board appointments
  • Contract appointments to serve as "on-call" expert witnesses
  • Taking a position in a related outside entity
  • Any other related outside activity where a signed contractual agreement will be required.
These activities should be disclosed and approved prior to initiating involvement in the activity and the disclosure should be updated if the activity is modified.

 

Who has to complete the OA disclosure?

All employees of OHSU are responsible for evaluating their outside activities and determining if they must be disclosed. Annual OA disclosure forms are now required only for the following groups of individuals, defined collectively as "disclosing employees":

Disclosing employees include:

  • OHSU Faculty members
  • OHSU Officers and Unit Leaders
  • Others serving in a management capacity at OHSU (including directors, supervisors, managers, and department administrators).
  • Persons who have delegated contracting authority or delegated fiscal authority over $100
  • Other persons designated by an OHSU Officer or Unit Leader

 

Where is the OA disclosure form?

If you are required to complete an annual OA disclosure as defined above, you must do so on-line in Big Brain.  This module includes an easy check-off if you are not involved in any outside activities requiring disclosure.  Big Brain will send out annual reminders so that the disclosure may be completed by the indicated due date. Revisions to disclosures should be submitted as needed.

 

Physician Payment "Sunshine Provisions"

OHSU Members should be aware that the Patient Protection and Affordable Health Care Act includes new "Sunshine Provisions," requiring pharmaceutical, medical device, biological, and medical supply manufacturers to begin reporting to the federal government the payments they make to physicians and teaching hospitals.

Additionally, the law requires the Secretary of Health and Human Services to make this payment and ownership interest information available on a publicly accessible, searchable, and downloadable website. As a result, manufacturers' payments to consultants, researchers, and others; physician ownership interests held in a manufacturer or Group Purchasing Organization; and important information related to such payments and disclosures, will now be a matter of public record.

The scope of reportable payments is broad and includes consulting fees, compensation for non-consulting services, honoraria,gifts, entertainment, food, travel, education, research, charitable contributions, royalties or licenses, current or prospective ownership or investment interests, direct compensation for serving as faculty or as a speaker for a medical education program, and grants.

Reporting requirements begin in March 2013.  However, some pharmaceutical companies have already begun to voluntarily post payments to healthcare professionals, including:  

 The Integrity Office will be monitoring these public databases to ensure that all payments received by physicians have been disclosed on the Conflict of Interest disclosure form(s) as appropriate, and that gifts in violation of the OHSU Gifts Policies have not been received.

Additional resources on the Physician Payment Sunshine Provisions:

 

Resources