OHSU members should visit the Financial Interests page on O2.
Certain financial interests must be disclosed.
Specifically, if they create a potential conflict of interest, which we define as: a financial interest or other obligation which interferes, or appears to interfere, with our member's obligations to act in the best interest of OHSU and it's missions, and without improper bias.
The scope of these interests is better understood by reviewing our definition of a Significant Financial Interest, which was adapted from the regulatory definition found in 42 CFR 50.603.
Anyone involved with research at OHSU must disclose all SFIs related to their institutional responsibilities, regardless if there is not a clear connection to their research. Additionally, those involved in Public Health Service funded research must make these disclosures within 30 days of acquiring or becoming aware of new SFIs.
Significant Financial Interests (SFIs)
The institution's criteria for an SFI includes the following interests of the discloser, the discloser's spouse or registered domestic partner, and any dependent children:
- Compensation: i.e., anything of monetary value including, but not limited to, salary, gifts, consulting fees, honoraria or other payments for services that is more than five thousand US dollars ($5,000) in the aggregate over the last twelve (12) months;
- Equity interests: e.g. stocks, stock options, warrants, contractual rights to acquire or receive ownership interests, or other ownership interests in a publicly-traded company that is more than five thousand US dollars ($5,000) or any amount in a non-publicly traded company;
- With respect to a publicly-traded company, the aggregated value of compensation over the last twelve (12) months and equity interest that is more than five thousand US dollars ($5,000);
- Intellectual property rights: e.g. patents, copyrights and royalty income or the right to receive future royalties under a patent license or copyright;
- Non-royalty payments or entitlements to payments in connection with the research that are not directly related to the reasonable costs of the research (e.g. bonus or milestone payments to the investigators in excess of reasonable costs incurred);
- Service as an officer, director, or in any other Executive Position in an outside business, whether or not remuneration is received for such service; and
- Reimbursed or sponsored travel (applies to investigators involved in PHS funded research only and not their spouse, registered domestic partner or dependent children). Disclosures shall include the purpose of the travel, the identity of the sponsor/organizer, the destination and the duration of the travel, and any other information as requested by the disclosure form or designated official.
The following interests are considered to be exceptions:
- Interests of any amount in publicly traded, diversified mutual funds or retirement accounts so long as the OHSU Member does not directly control the investment decisions made in these vehicles.
- Payments to the institution, or via the institution to the individual, that are directly related to reasonable costs incurred in the conduct of research as specified in the research agreement(s) between the sponsor and the institution.
- Salary and other remuneration from OHSU, including approved faculty practice plan earnings and the distribution of those earnings that may be established by departmental or other similar agreements provided that those agreements and departmental/divisional group plans are approved by the President.
- Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education; or
- Income from service on advisory committees or review panels for a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
- Reimbursed or sponsored travel that is reimbursed or sponsored by a federal, state or local government agency, an Institution of higher education, an academic teaching hospital, or a research institute that is affiliated with an Institution of higher education.
Where do I complete my disclosure?
Visit the eCoI system to submit a disclosure.
For more information about that system, visit our Conflict of Interest system page.