Service Related

Conflict of Interest
Policy Scorecard

Georgetown University School of Medicine

Service Related COI Grade:

Fee-For-Service Policy:

Self-Referral Policy:

Policy absent or unlikely to have substantial impact

Model policy

Policy Excerpt:

"Typically, a financial conflict of interest may arise when a person has the opportunity to influence University business, administrative, academic, or other decisions in ways that could lead to personal gain or advantage of any kind. A conflict of interest may also exist when a person has a SIGNIFICANT FINANCIAL INTEREST in a BUSINESS from which he or she receives SPONSORED PROGRAM support or whose value may be affected by research in which the person participates.

While it is difficult to specify precisely what constitutes an objectionable conflict in all situations, the guidelines set forth below establish general standards by which individuals must evaluate their behavior. The guidelines are divided into three categories: (1) conduct presumptively prohibited; (2) conduct permitted only after review and approval; and (3) conduct merely requiring disclosure. The guidelines are not exhaustive of all potential conflict of interest situations. Where facts known to a person reasonably suggest an actual or apparent conflict of interest, the person is expected to disclose the circumstances and avoid the conflict of interest in good faith consistent with the spirit and objectives of this Policy.

1. Conduct Presumptively Prohibited

This section of the guidelines describes conduct that is "presumptively prohibited". Presumptively prohibited conduct presents a prima facie conflict of interest and may not ordinarily be engaged in by any person covered under this Policy. The presumption may be rebutted and the conduct permitted if the person establishes by clear and persuasive evidence that such permission is justified by compelling circumstances. The following factors, among others, may be considered in evaluating whether the person has made a sufficient showing of compelling circumstances: the nature of the research or educational activities or the University business involved; the magnitude of the interest and the degree to which it is related to the research or educational activities or the University business involved; in clinical research, the degree of risk to the human subjects involved that is inherent in the research; and the extent to which the interest is amenable to effective oversight and management. Section D (and, where applicable Appendices B and C) of the Policy, set forth the applicable processes for review and approval in such cases.

a. SIGNIFICANT FINANCIAL INTEREST in a Business

If a person, a member of his or her FAMILY, or an ASSOCIATED ENTITY possesses a SIGNIFICANT FINANCIAL INTEREST (other than a CONSULTING RELATIONSHIP) in a BUSINESS, then the person may not

(1) receive SPONSORED PROGRAM support from the BUSINESS; or

(2) assign students, postgraduate students, fellows or other trainees to projects supported wholly or partially by SPONSORED PROGRAM funding from the BUSINESS.

b. Participation in University Decisions

A person may not participate in any University decision that relates to or has any effect on a BUSINESS (1) in which the person, a member of the person's FAMILY, or an ASSOCIATED ENTITY has a SIGNIFICANT FINANCIAL INTEREST or (2) with which the person, a member of the person’s FAMILY, or an ASSOCIATED ENTITY has or is negotiating to have any paid consulting or employment relationship. Under such circumstances, a person shall promptly and fully disclose the conflict and recuse himself or herself from any participation in such a decision."

"2. Conduct Permitted Only After Review and Approval

This section of the guidelines describes conduct a person may engage in only after review and approval in accordance with Section D of the Policy. The factors specified in Section B.1 above may also be considered in addressing requests under this section.

a. SIGNIFICANT FINANCIAL INTEREST in a BUSINESS

If a person, a member of his or her FAMILY or an ASSOCIATED ENTITY possesses a SIGNIFICANT FINANCIAL INTEREST (other than a CONSULTING RELATIONSHIP) in a BUSINESS, then unless he or she first discloses the SIGNIFICANT FINANCIAL INTEREST and receives approval in accordance with Section D of the Policy, the person may not

(1) engage in research on projects that, whether or not sponsored by the BUSINESS, involve TECHNOLOGY owned by or contractually obligated (for example, through a license) to the BUSINESS;

(2) assign students, post-graduate students, fellows or other trainees to projects listed in Section B.2.a(1) above; or,

(3) make clinical referrals to such a BUSINESS."

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