UNIVERSITY OF PITTSBURGH POLICY 11-01-03

CATEGORY:         RESEARCH ADMINISTRATION
SECTION:          Research
SUBJECT:          Conflict of Interest - Research/Teaching
EFFECTIVE DATE:   June 21, 1996 (Revised April 4, 1997)
PAGE(S):          10

I.   INTRODUCTORY NOTE
     
     In recent years many University faculty have taken on functions
     outside their traditional domain of teaching and scholarship.
     Technology transfer and public service involvement of various
     kinds are encouraged by the government and seem necessary for the
     public good.  There is the potential for good as well as for
     serious conflicts of interest to emanate from such endeavors.
     The federal government presently regulates conflicts of interest
     pertaining to government grants by requiring that universities
     maintain a written policy in the area.*  This policy is
     consistent with those regulations.**
     
     Regular and timely full disclosure of potential conflicts is at
     the heart of the policy.  The most difficult conflicts of
     interest in research arise not because of a clash of "good versus
     evil," but often because of a clash of "good versus good."  Two
     desirable outcomes, or the procedures necessary to achieve such
     outcomes, cannot always be reconciled.  On the other hand, when
     outcomes or procedures appear clearly wrong and they are in
     conflict with generally accepted values, commitments, or norms,
     the solution is much simpler.  The wrongful behavior should be
     stopped immediately.  Formulating policies and procedures to
     manage, reduce, or eliminate potential or real conflicts of
     interest (or conflicts of commitment) among faculty,
     administrators, or investigators requires that the University
     delineate the value structure to which it and its faculty,
     administrators, and investigators must adhere.  Fortunately,
     these values and professional norms are not difficult to
     state.***
     
     Faculty, administrators, and investigators are expected to share
     a commitment to at least these values:
     
     -    a genuine commitment to teaching and research and to the
          institution
     -    academic freedom
     -    intellectual independence
     -    diversity
     -    open communication and dissemination of knowledge
     -    competence and integrity in research and education
     -    public service
     -    serving as examples to society
     
     Given such commitments, there can, from time to time, be
     conflicts among them generated by the activities of faculty,
     administrators, and investigators who seek to advance their
     scholarly work and themselves.  This document deals primarily
     with conflicts of interest while conflicts of commitment are
     mentioned only when they result from or have a bearing on a
     conflict of interest.
     
     The following examples illustrate potential or actual conflicts
     of interest:
     
     1.   Accepting gratuities or special favors related to teaching,
          research, or administrative duties.
     
     2.   Giving well paid lectures for companies or organizations
          whose economic or political interests are affected by an
          investigator's scholarly work.
     
     3.   Undertaking evaluative research when the investigator or the
          investigator's dependents have a financial, managerial, or
          ownership interest in the sponsoring company or in the
          company producing the product tested.
     
     4.   Entering into a paid consultantship arrangement with an
          organization or individual having an economic interest in
          related research.
     
     5.   Using students or employees of the institution to perform
          services for a company in which a faculty member has an
          ownership interest or from which he/she receives any type of
          remuneration.
     
     6.   Assigning as required texts in their course, books for which
          the instructor derives significant financial benefits.
     
     7.   Accepting support for research under terms and conditions
          that results be held confidential, unpublished, or
          significantly delayed in publication.
     
     8.   Providing privileged access to information, developed with
          University resources or supported by independent sponsors,
          to an entity in which the faculty member, investigator, or
          administrator has a political or financial interest.
     
     9.   Purchasing equipment, instruments, or supplies for research
          or teaching from a firm in which the faculty member,
          investigator, or administrator has a financial or other
          interest.
     
     10.  Influencing the negotiation of contracts between the
          academic institution and outside organizations with which a
          faculty member, investigator, or administrator has a
          financial interest or other relationship.
     
     The above examples are by no means exhaustive, but they are
     exemplary of potential conflicts of interest that must be
     disclosed, forsworn, or otherwise managed, reduced, or eliminated
     prior to the materializing of the conflict.
     
     The University will require timely, full, and mandatory
     disclosure of faculty's, administrators', or investigators'
     outside relationships and organizational commitments to identify
     and manage, reduce, or eliminate any conflicts.  Full and timely
     disclosure by faculty, administrators, or investigators will
     sensitize them, chairs, and deans to potential conflicts of
     interest and promote management, reduction, or elimination of
     actual conflicts.
     
     The University will develop awareness of the Conflict of Interest
     Policy and Procedures in several ways:
     
     1.   Presentations to all department chairs and deans;
     
     2.   Publication of the policy and procedures in the Policy and
          Procedures Manual of the University and dissemination to all
          current faculty, investigators, and administrators at
          departmental meetings where a discussion will be held about
          the policy and procedures;
     
     3.   Incorporation of an explanation of the policy and
          procedures, including their importance, mechanisms, and
          standards, into the orientation program for new faculty, and
          at the time of annual review of faculty performance;
     
     4.   Emphasis by deans and department chairs of the need for
          consistent and equitable adherence to the policy and
          procedures by all deans, department chairs, faculty,
          administrators, and investigators;
     
     5.   Faculty participation through the University Senate
          representatives on the Conflict of Interest Committee; and
     
     6.   Monitoring by the Conflict of Interest Committee.
     
     The policy assures that potential conflicts routinely come to the
     attention of department chairs and deans, who have historically
     settled such issues and will continue to do so in most cases.
     However, the policy does not and cannot have explicit
     prescriptions for all acceptable and unacceptable conflicts.
     Potential conflicts that do not yield to settlement attempts by
     the deans and department chairs, will be passed on to the Senior
     Vice Chancellors who may seek guidance from the Conflict of
     Interest Committee.
     
     It is the task of the Conflict of Interest Committee to
     investigate novel or difficult situations in light of the general
     guidelines of the Conflict of Interest Policy and federal
     regulations in order to provide the referring Senior Vice
     Chancellor with the best impartial and informed advice.
     
     The Chair of the Conflict of Interest Committee, appointed by and
     reporting to the Chancellor of the University, shall work closely
     with the academic administrators in ensuring procedural
     compliance with the Conflict of Interest Policy and associated
     government regulations.  The Chair of the Conflict of Interest
     Committee shall make or supervise all contacts with government
     agencies or other outside parties and shall maintain a record of
     all proceedings.
     
     The Conflict of Interest Committee will review and recommend
     revisions to the Conflict of Interest Policy as appropriate.
     
II.  GENERAL PRINCIPLES
     
     -    Recognition that not all conflicting interests are
          necessarily impermissible.
     
     -    Reliance on complete, timely disclosure.  Disclosure, but
          not necessarily prohibition, of financial interests and
          remunerations, where applicable.
     
     -    Case by case analysis.
     
     -    Accountability at all levels of review -- up to and
          including the Chancellor.
     
     -    Assurance of confidentiality (save for disclosure to
          superiors within a structure of accountability and to
          federal funding agencies when required under terms of the
          grant, contract, or cooperative agreement).
     
     -    Timely, but not less than annual, review and analysis of
          conflicts managed, reduced, or eliminated.
     
III. DEFINITIONS, POLICY,**** AND GUIDELINES
     
     In general, conflicts of interest relate to the potential for
     self-gain usually, but not always, of a fiscal nature.  Potential
     for self-gain might serve to undermine the judgment or
     objectivity of faculty, administrators, or investigators such
     that their primary mission and dedication to academic values and
     activities of the University are compromised.  Furthermore, not
     only bias, but the appearance of bias in research, may undermine
     public trust in the University.
     
     The opportunity for investigators or scholars to receive
     financial or other personal rewards from their endeavors is not
     intrinsically unacceptable, as long as it does not adversely
     affect the objectivity, integrity, or professional commitment of
     an investigator.  Hence, participation in a situation with
     opportunity for personal gain does not constitute an unacceptable
     situation of itself; it is the potential stimulus for
     unacceptable behavior that must be addressed.
     
     A.   Definitions
     
          1.   Conflict of Interest*****
     
               A potential or actual conflict of interest exists when
               commitments and obligations to the University or to
               widely recognized professional norms are likely to be
               compromised by a person's other interests or
               commitments, especially economic, particularly if those
               interests or commitments are not disclosed.  Federal
               Regulations provide that a conflict of interest exists
               if the reviewer(s) of disclosures determines that a
               significant financial interest could "directly and
               significantly affect the design, conduct, or reporting"
               of federally funded activities.
     
          2.   Members of the Immediate Family
     
               Dependents, the spouse, and all members of the
               household are considered members of the immediate
               family.  Circumstances or relationships that must be
               disclosed or managed, reduced, or eliminated as to a
               faculty member, administrator, or investigator usually
               must also be disclosed or managed, reduced, or
               eliminated if the faculty member, administrator, or
               investigator knew or should have known that a member of
               his or her immediate family had such a relationship.
     
          3.   Administrators
     
               "Administrators" in the context of this document
               includes all administrative employees, even if they do
               not hold faculty rank, who direct or can materially
               influence research.
     
          4.   Investigators
     
               Investigators includes all employees who are
               responsible for the design, conduct, and reporting of
               research.
     
     B.   Policy
     
          1.   Faculty members, administrators, and investigators are
               required to make regular, timely, and full confidential
               disclosures to their superior, using the disclosure
               form(s) included with this policy.  This will generally
               include disclosure of all outside remunerative
               activities related to their teaching, research, or
               administrative responsibilities.  They must also
               disclose equities and positions of members of their
               immediate family which could create a conflict or the
               perception of a conflict of interest between their
               academic obligations and their outside interests.
     
          2.   The Conflict of Interest Policy also imposes the
               obligation on department chairs, and other supervisory
               administrators -- themselves subject to the policy and
               its disclosure requirements -- not to encourage or
               condone impermissible conflicts on the part of their
               faculty, administrators, or investigators.
     
          3.   Sanctions may be applied for non-compliance with the
               requirements or provisions of this policy in the same
               way as for non-compliance with any other University
               policy, including removal from the particular project,
               letter of reprimand, special monitoring of future work,
               probation, suspension, salary reduction, or initiation
               of steps leading to possible rank reduction or
               termination of employment.
     
     C.   Guidelines
     
          1.   Obligations
     
               A person who accepts a regular appointment to the
               faculty, the administration, or to a research position
               has an obligation to devote his/her primary
               professional effort to the University to the extent
               required by the appointment or research position.
               Other activities or commitments must be arranged so as
               not to conflict with or dilute this commitment.  While
               employment outside the contract period (i.e., summer
               employment) may not represent a conflict of commitment,
               it can generate a conflict of interest.
     
          2.   Confidentiality
     
               In order to encourage full disclosure of potential
               conflicts without unduly intruding on the privacy of
               University personnel or their families, disclosures
               shall be treated confidentially and disclosed only to
               the extent necessary for review, to consider and
               manage, reduce, or eliminate any conflicts, and to
               comply with requests from federal funding agencies made
               in accordance with the terms of the grant, contract, or
               cooperative agreement.
     
          3.   Subsequent Disclosure
     
               Financial, personal, or professional relationships that
               raise a potential conflict of interest or its
               perception shall be fully and accurately disclosed in
               all formal communications relating to the sponsored
               research, including those in professional journals.
     
          4.   Withdrawal from Decisions
     
               Faculty, administrators, and investigators shall not
               exercise decision-making authority or exert influence
               concerning any University relationship affecting a
               company in which they or members of their immediate
               family have a personal or professional interest.
     
          5.   Technology Transfer
     
               The commercialization and the transfer of technology
               can create conflicts of interest.  Rules pertaining to
               technology transfer are published in the University
               Technology Transfer Policy (11-02-01).
     
     D.   Encouraging Openness and Exchange of Information
     
          1.   The free exchange of information is a fundamental value
               underlying the University's mission.  Faculty,
               administrators, and investigators have the general
               right to know the nature, purposes, methods, results,
               and sponsorship of relevant research conducted within
               the University.
     
          2.   In order to avoid broad limitations on collegial
               communication, arrangements involving the receipt of
               confidential scientific information, which may not be
               shared with colleagues reasonably promptly, shall be
               kept to a minimum.  Where such arrangements are
               unavoidable, the scope of the project shall be defined
               so as to permit the exchange of as much information as
               possible.
     
          3.   Insofar as possible and in accordance with the
               University Research Integrity Policy (11-01-01),
               University guidelines on externally sponsored research,
               and the University Technology Transfer Policy (11-02-
               01), all significant results of research shall be
               published or publicly disclosed with reasonable
               promptness whether the results are favorable or
               unfavorable to the interests of any sponsor.  Certain
               restrictions or limited delays in dissemination of
               information may be warranted by scientific prudence,
               the need to prepare patent applications, other legal
               rights, or for other justifiable reasons.
     
     E.   Assignment of Students and Staff
     
          1.   Staffing of sponsored research is subject to University
               policies, and sponsors may not interfere with staffing
               decisions.
     
          2.   Students and post-doctoral fellows shall not be
               exploited or their education compromised in the service
               of sponsored research or the financial gain of the
               supervisor.  Employment of students or fellows by
               companies in which their faculty supervisor has
               economic interests must be disclosed on Part II of the
               Disclosure Form by the student's academic supervisor.
     
          3.   Faculty shall take all precautions necessary to ensure
               that their students' progress and academic standing are
               not jeopardized by violations of any professional norms
               in projects in which they participate, or by students'
               naivete as to the circumstances surrounding
               industrially sponsored research.
     
     F.   Compensation to Clinical Investigators
     
          Compensation arrangements for support of clinical studies
          shall not adversely affect the conduct or influence the
          outcome of clinical research.
     
IV.  PROCEDURES
     
     Disclosure of outside interests and commitments by faculty
     members, administrators, and investigators to their chairs,
     deans, or direct higher level supervisors shall be made upon
     appointment and each April 15 thereafter or when a conflict
     arises during the year.  In special situations, a faculty member,
     administrator, or investigator may request that the dean (rather
     than the department chair) provide the initial review of the
     information disclosed.  The dean will then rule whether the
     information must also be disclosed to the department chair.
     
     If chairs or other superiors perceive that they have a "conflict
     of interest" in reviewing disclosed information, they shall
     disqualify themselves and request that the review be done by
     their superiors.
     
     Review after disclosure must take place promptly and help
     faculty, administrators, and investigators determine which
     interests are not in conflict, which conflicting interests may be
     permissible, and which conflicting interests place the faculty
     member, administrator, or investigator at risk of jeopardizing
     the integrity of his/her academic or administrative work.
     
     The choice of full disclosure in place of categorical
     prohibitions is based on the assumption that once a conflict is
     recognized, it can be avoided or managed, reduced, or eliminated.
     Disclosures shall be kept confidential, except to the extent
     necessary to review, consider, and manage, reduce, or eliminate
     any conflicts.  The conflict of interest definition, guidelines,
     and procedures shall be read and interpreted at all times in
     coordination with the University Research Integrity Policy (11-01-
     01), the Policy on Outside Professional Service (02-06-01), the
     Technology Transfer Policy (11-02-01), Continuing Medical
     Education guidelines, and other relevant policies.
     
     A.   Faculty Members, Administrators, and Investigators
     
          1.   Every faculty member, administrator, and investigator
               must complete on an annual basis the Statement of
               Outside Interests and Activities (Part I of Disclosure
               Form) and submit it on or before April 15 or when a
               conflict arises during the year to his/her supervisor;
               i.e., the department chair or dean, as appropriate.  If
               in the judgment of the faculty member, administrator,
               or investigator a potential or actual conflict arises,
               the Disclosure Form shall be updated promptly.  The
               superiors receiving these forms are required to keep
               them in a secure place for at least three years after
               the filing of the final financial reports of relevant
               funded projects or longer if required by the funding
               agencies.
     
          2.   Every faculty member, administrator, and investigator
               must submit a current copy of the Statement of Outside
               Interests and Activities to the department chair or
               dean with each proposal for research funding.  A
               current copy of Part I should remain in the Office of
               Research for at least three years after the filing of
               the final financial reports of relevant funded projects
               or longer if required by the funding agencies.
     
          3.   As required by the University policy on outside
               professional service, faculty members, administrators,
               and investigators shall also discuss, prospectively,
               with their superiors any planned outside interests and
               activities that have the potential to conflict with,
               could appear to be in conflict with, or are in conflict
               with their commitment to the University or to their
               research for the purpose of managing, reducing, or
               eliminating the potential or actual conflict.
     
     B.   Department Chairs or Deans
     
          1.   The chairs or deans, as the case may be, shall maintain
               in confidence all Statements of Outside Interests and
               Activities submitted to them by faculty members,
               administrators, and investigators, except for the
               disclosure which is authorized by this Conflict of
               Interest Policy.
     
          2.   They shall:
     
               a.   review all faculty's, administrators', and
                    investigators' Statements of Outside Interests and
                    Activities for real, apparent, or potential
                    conflicts of interest; and request and document
                    additional details including precise dollar
                    figures for ownership interests or remuneration if
                    such details appear necessary for a sound
                    determination of the presence or absence of an
                    impermissible conflict of interest;
     
               b.   notify their superiors and the Chair of the
                    Conflict of Interest Committee of the fact that
                    specific faculty members, administrators, or
                    investigators have outside interests, based on
                    affirmative answers in Part I of the Disclosure
                    Form and additional details in Part II of the
                    Disclosure Form;
     
               c.   determine whether their superiors wish to review
                    the detailed information of outside interests
                    provided by faculty members, administrators, or
                    investigators and, if so, notify them that the
                    superior will be reviewing the Disclosure Form
                    they have submitted;
     
               d.   meet with individual faculty, administrators, or
                    investigators to discuss collegially how potential
                    or actual conflicts shall be managed, reduced, or
                    eliminated;
     
               e.   recommend and initiate action to manage, reduce,
                    or eliminate the apparent, potential, or real
                    conflict within 60 days of disclosure or refer it
                    to the next higher level; and
     
               f.   recommend and initiate action leading to sanctions
                    for non-compliance with proposed management,
                    reduction, or elimination of a conflict.
     
          3.   Any faculty member, administrator, or investigator who
               disagrees with the recommendation of his/her superior
               for managing, reducing, or eliminating conflicts of
               interest may appeal to the next higher level of
               administration as specified below.  As a second step,
               the grievance procedure of the Faculty Handbook may be
               followed.
     
          4.   Department chairs, deans, other administrators, or the
               Senior Vice Chancellors may demand disclosure by
               faculty, administrators, and investigators of all
               outside income related to professional
               responsibilities, regardless of any threshold amount
               specified in the Statement of Outside Interests and
               Activities.
     
          5.   The enforcement of this policy on conflict of interest
               rests primarily with the academic unit where the
               research is conducted.  The immediate supervisor of the
               faculty member, administrator, and investigator should
               be cognizant of the activities taking place in the unit
               and should monitor the research as to potential and
               actual conflicts of interest.  Reviews conducted by the
               supervisor, as appropriate but no less than annually,
               should contain questions probing the conflict of
               interest issue.  The listing given in the Introductory
               Note of the policy highlights some conflict of interest
               areas of concern.  Some examples of appropriate actions
               to resolve conflicts of interest are:
     
               a.   Public disclosure of significant financial
                    interests in publications and presentations.
     
               b.   Monitoring of research by independent reviewers.
     
               c.   Modification of the research plan.
     
               d.   Disqualification from participation in all or a
                    portion of the funded research.
     
               e.   Divestiture of significant financial interests.
     
               f.   Severance of relationships that create actual or
                    potential conflicts.
     
          6.   In the event that a conflict of interest related to a
               federally funded project is identified after the
               project is underway, the immediate supervisor of the
               faculty member, administrator, or investigator shall
               notify the Chair of the Conflict of Interest Committee
               of the conflict who will report to the federal agency
               within 60 days that a conflict exists and action is
               being taken to manage, reduce, or eliminate the issue.
     
     C.   Annual Summary Reports
     
          1.   The department chairs and deans, as the case may be,
               shall submit an annual report of largely anonymous data
               to their respective superiors and the Chair of the
               Conflict of Interest Committee by December 31 of each
               year.  These data shall include the following:
     
               a.   the number and percentage of department faculty,
                    administrators, and investigators who have had to
                    submit detailed Statements of Outside Interests
                    and Activities (Part II);
     
               b.   concerning each question on the Statement of
                    Outside Interests and Activities, the number and
                    percentage of department faculty, administrators,
                    and investigators who have affirmatively answered
                    each question;
     
               c.   the number and percentage of department faculty,
                    administrators, or investigators whose outside
                    interests and activities were found to be in
                    conflict with their University and/or professional
                    commitments, and whose conflicts were managed,
                    reduced, or eliminated;
     
               d.   the number and percentage of any faculty's,
                    administrators', or investigators’ conflicts of
                    interest which were not managed, reduced, or
                    eliminated; and
     
               e.   details regarding remedial action recommended and
                    taken.
     
          2.   The deans or directors of all units shall be
               responsible for submitting an annual review of the data
               summary of their unit’s Statements of Outside Interests
               and Activities to their Senior Vice Chancellor for
               independent or collaborative evaluation of the unit’s
               outside interests and activities that present real,
               apparent, and/or potential conflicts of interest.  The
               deans have the right and authority to request from the
               department chairs the complete Statement of Outside
               Interests and Activities of any faculty member,
               administrator, or investigator within the respective
               schools.
     
     D.   Review Procedure
     
          1.   At the request of the faculty members, administrators,
               investigators, or department chairs within their
               schools, the deans evaluate the recommendations made by
               the chairs and decide whether additional or different
               action is necessary to prevent, manage, reduce, or
               eliminate conflicts of interest.  If the faculty
               member, administrator, investigator, or department
               chair is still dissatisfied with the determination of
               the dean regarding a potential conflict of interest,
               the faculty member, administrator, investigator, or
               department chair may request the dean to present the
               matter to the Senior Vice Chancellor for the Health
               Sciences or to the Provost's Office for review,
               consideration, and recommendation of action to prevent,
               manage, reduce, or eliminate the conflict in a timely
               fashion after receiving the request.
     
          2.   The Provost of the University has the ultimate
               authority to determine how conflicts of interest should
               be prevented, managed, reduced, or eliminated and to
               approve sanctions for non-compliance with proposed
               management, reduction, or elimination of conflicts.
               The Provost may utilize the assistance of the Conflict
               of Interest Committee in arriving at decisions.
     
________________

*It should be noted that this policy covers Conflicts of Interest on
research/teaching issues as distinguished from the policies on
Conflict of Interest for Consultants, Conflict of Interest for
Designated Administrators and Staff, and the Conflict of Interest and
Procurement Relationships.

**National Science Foundation Grants Policy Manual - Investigator
Financial Disclosure Policy, October 1, 1995, and Public Health
Service Regulations codified at 42 CFR Part 50, and 42 CFR Part 94.

***Some of the language of this discussion has been taken from the
"Guidelines for Dealing with Faculty Conflicts of Commitment and
Conflicts of Interest in Research" by the Association of American
Medical Colleges, Copyright 1990, ACM Washington, DC.

****This policy is a generalized and abbreviated version of the
proposal by the Conflict of Interest Committee, University of
Pittsburgh, Health Sciences Schools, with amendments by the University
Research Council and the TAF Senate Committee.  Some of the language
of the proposal and of this policy has been taken from the "Guidelines
for Dealing with Faculty Conflicts of Commitment and Conflicts of
Interest in Research" by the Association of American Medical Colleges,
Copyright 1990, ACM Washington DC.  The policy is accompanied by an
Introductory Note that presents examples and background.

*****Conflicts of Interest in Academic health Centers:  Policy Paper
#1.  Association of Academic Health Centers, Washington, DC:  1400
Sixteenth Street, NW, Suite 410, Washington, DC 20036 (1990).  These
definitions of conflict of interest and the guidelines stated below
were formulated in 1990 by the Association of Academic Health Centers.
The definition and guidelines are being used with the permission of
the Association.  Some revisions have been made to adapt the language
of the definition and guidelines to the University of Pittsburgh.





                             CONFIDENTIAL
                                   
    University of Pittsburgh disclosure form for calendar year 2002
                     FOR RESEARCHERS AND TEACHERS
                                   
                     (University Policy 11-01-03)
         http://www.pitt.edu/HOME/PP/policies/11/11-01-03.html


PART I

Only those outside interests related to University activities need to
be reported.  Not all outside interests and financial relationships
place the faculty member, administrator, or investigator in conflict
with each person’s obligations to the University and to his or her
profession.  Not all conflicting interests are necessarily
impermissible.  Timely and complete disclosure of potential conflicts
of interest protects you from suspicion and accusations of breach of
academic integrity.

STATEMENT OF OUTSIDE INTERESTS AND ACTIVITIES


NAME ______________________________     DATE _________________________
     (Please type or print clearly.)

SCHOOL ____________________________     DEPARTMENT ___________________
     (e.g., Engineering, Nursing, etc.)

CAMPUS ADDRESS/PHONE _________________________________________________


Purpose:
The purpose of this disclosure statement is for faculty members,
administrators, and investigators of the University to ensure that no
unresolved conflict exists between their primary University
commitments and their outside interests and activities.  This
statement conforms with current federal guidelines requiring
disclosure for professional activities of faculty members,
administrators, and investigators.  This statement establishes
specific facts to help supervisors (e.g., the department chairs,
deans, Senior Vice Chancellor for Health Sciences or the Provost) to
determine whether a potential conflict exists so that they may manage,
reduce, or eliminate the problem.

Procedure:
All faculty members, administrators, and investigators must complete
this form annually and submit it to their department chair or dean for
review and approval.  All Part I declarations must be submitted to the
Office of Research on or before April 15.  Part II declarations, where
required, must be submitted, with corresponding management plans, to
the Senior Vice Chancellor for Health Sciences or Provost by May 15.
In addition, faculty and other professional employees who conduct or
administer research supported by external funds must submit a current
copy of Part I and, if applicable, Part II of this form to their
department chair or dean, as appropriate, with each proposal for
funding and when they believe new facts create a potential or actual
conflict of interest.

1.   Ownership Interests
     
     During the past calendar year, did you or members of your
     immediate family,* own or control an equity interest in any
     organization** in your field of academic interest or
     specialization that when aggregated for you, your spouse and
     dependent children exceeded a 5% ownership interest or is greater
     than $10,000?

          YES _____ NO _____


2.   Offices and Positions
     
     During the past calendar year, were you or a member of your
     immediate family, a director, officer, partner, employee, or
     agent, or in any managerial position in any organization outside
     the University of Pittsburgh that might be affected by your
     research or administrative activities?  You need not answer with
     respect to governmental committees, community, political,
     academic, charitable, religious, social or professional nonprofit
     organizations.

          YES _____ NO _____


3.   Remunerative Activities
     
     Does income (cash or in-kind, other than reimbursement of
     reasonable expenses) related to your teaching, research, or
     administrative activities received by you during the past year or
     expected over the coming year from any one organization outside
     the University exceed 1% of your University salary or does income
     aggregated for you, your spouse, and dependent children received
     from such an organization during the past year or expected over
     the coming year exceed $10,000?  (NOTE: UPP members do not need
     to report practice plan salary.)

          YES _____ NO _____


4.   Outside Employment of Students or Staff
     
     Do you now, or did you during the past calendar year, employ any
     of your students or staff in a company or organization outside
     the University?

          YES _____ NO _____


5.   Technology Transfer Activities
     
     Are you or a member of your immediate family the inventor of any
     technology for which an invention disclosure has been filed or
     which is being developed or evaluated in connection with your
     research activities?

          YES _____ NO _____


6.   Other Transactions or Facts
     
     During the past calendar year, did you or any member of your
     immediate family have an interest in any contract, sale, or other
     transaction to which the University of Pittsburgh or one of its
     affiliates was a party, or are there other situations, not listed
     above, that you believe may create an actual or perceived
     conflict of interest?  (Exclude your own or your spouse’s
     employment contract with the University.)

          YES _____ NO _____


I have reviewed the Conflict of Interest Policy for Researchers and
Teachers and attest that I have made a complete and accurate statement
of my reportable outside interests and activities.  Furthermore, I
understand and accept my obligation to disclose, in a timely fashion,
any subsequent change in financial interest status which may present
the potential for perceived conflict of interest according to
University policy.


NAME ______________________________     DATE _________________________
     (Please type or print clearly.)

SIGNATURE ____________________________________________________________


PLEASE NOTE: Sanctions may be applied for non-compliance with the
requirements or provisions of this policy in the same way as for non-
compliance with any other University policy, including removal from
the particular project, letter of reprimand, special monitoring of
future work, probation, suspension, salary reduction, or initiation of
steps leading to possible rank reduction or termination of employment.


Supervisor’s Statement

___  I certify that the person named above reports to me and to the
     best of my knowledge has made full disclosure, does not have any
     conflicts of interest, and does not need to file a Part II
     declaration.

OR

___  I certify that the person named above reports to me, has made a
     full disclosure, and has filed a Part II declaration.


NAME _______________________________    TITLE _______________________
     (Please type or print clearly.)

SIGNATURE __________________________    DATE ________________________


======================================================================

IF YOU ANSWERED “YES” TO ANY OF THE QUESTIONS OF PART I, YOU MUST
COMPLETE THE RELEVANT SECTIONS OF PART II.

======================================================================



* Dependents, the spouse, and all members of the household are
considered members of the immediate family.
** “Organization” includes any corporation, partnership,
proprietorship, firm, enterprise, franchise, association, trust,
government agency, or other entity but does not include mutual funds
over which you have no control.





COMPLETE PART II ONLY IF YOU ANSWERED “YES” TO ANY QUESTIONS IN PART I

    University of Pittsburgh disclosure form for calendar year 2002
                     FOR RESEARCHERS AND TEACHERS
                                   

PART II – CONFIDENTIAL DISCLOSURES
Detailed Statement of Outside Interests and Activities

NAME ______________________________     DATE _________________________
     (Please type or print clearly.)

SCHOOL ____________________________     DEPARTMENT ___________________
     (e.g., Engineering, Nursing, etc.)

1.   Ownership Interests
     
     If, during the past calendar year, you or members of your
     immediate family* owned or controlled (in aggregate) an equity
     interest in any organization** in your field of academic interest
     or specialization that exceeded a 5% ownership interest or is
     greater than $10,000, give details below.

                       City &        Nature of         Relationship of
     Organization      State         Business          Family Member











2.   Offices and Positions
     
     Please give details if, during the past calendar year, you or a
     member of your immediate family, were a director, officer,
     partner, employee, or agent, or in any managerial position, in
     any organization outside the University of Pittsburgh that might
     be affected by your research or administrative activities.  (You
     need not include governmental committees, community, political,
     academic, charitable, religious, social or professional nonprofit
     organizations.)

                                     Nature of         Relationship of
     Organization      Position      Business          Family Member










3.   Remunerative Activities
     
     Please give details of income (cash or in-kind, other than
     reimbursement of reasonable expenses) related to your teaching,
     research or administrative activities received by you during the
     past year or expected over the coming year from any one
     organization outside the University exceeding 1% of your
     University salary.  Please also give details of income aggregated
     for you, your spouse, and dependent children received from any
     one organization outside the University during the past year or
     expected over the coming year exceeding $10,000.

                                               Remunerative Code
     Organization      Nature of Business      – A, B or C*








     *Remunerative Code: A = exceeds $10,000, B = exceeds 1% of
     salary, C = exceeds both

4.   Outside Employment of Students or Staff
     
     Please give details if you now, or during the past calendar year,
     employed any of your students or staff in a company or
     organization outside the University.

                                                     Effort
     Staff or Student Name     Employer              (Hours/Year)








5.   Technology Transfer Activities
     
     If you answered YES to the the Technology Transfer question in
     Part I, please give a brief description of the technology in
     which you have an interest and any license agreements or other
     technology transfer agreements entered into for that technology.
     Even if you have not yet received any financial remuneration for
     the technology, please list those agreements for which you would
     be entitled to share in commercial proceeds under University of
     Pittsburgh or other institutions’ technology transfer policies.








6.   Other Transactions or Facts
     
     Please give details if during the past calendar year you or any
     member of your immediate family had an interest in any contract,
     sale or other transaction to which the University of Pittsburgh
     or one of its affiliates was a party.  In addition, if there are
     other situations, not covered in questions 1-5 above that may
     create an actual or perceived conflict of interest, please
     explain?  (Exclude your own or your spouse’s employment contract
     with the University.)  Please identify such transactions or
     facts, including date, parties, subject matter, etc.







I attest that the above is an accurate and current statement of all my
reportable outside interest and activities.


NAME ______________________________     DATE _________________________
     (Please type or print clearly.)

SIGNATURE ____________________________________________________________


Supervisor’s Statement

___  I certify that the person named above reports to me and to the
     best of my knowledge has made full disclosure.  I have reviewed
     this form, discussed the contents with the individual and find no
     reason for further action.  This form (Part II only) and other
     supporting information will be forwarded to the Dean/Campus
     President for further review.  (Part I must be sent to the Office
     of Research.)

OR

___  I certify that the person named above reports to me.  The
     individual and I have been unable to reach a satisfactory
     resolution of their potential conflict of interest.  I am
     forwarding this form (Part II only) along with supporting
     information to the Dean/Campus President for his/her
     adjudication.  (Part I must be sent to the Office of Research.)


NAME _______________________________    TITLE _______________________
     (Please type or print clearly.)

SIGNATURE __________________________    DATE ________________________

Please note: All Part II disclosures and supporting material are
forwarded to the Dean or Campus President and then to the Provost or
Senior Vice Chancellor for the Health Sciences for their reviews and
then are placed in a confidential database.  The information will be
treated confidentially and disclosed only to the extent necessary for
review, to consider and manage, reduce, or eliminate any conflicts,
and to comply with requests from federal funding agencies made in
accordance with the terms of the grant, contract, or cooperative
agreement.

Furthermore, sanctions may be applied for non-compliance with the
requirements or provisions of this policy in the same way as for non-
compliance with any other University policy, including removal from
the particular project, letter or reprimand, special monitoring of
future work, probation, suspension, salary reduction, or initiation of
steps leading to possible rank reduction or termination of employment.




* Dependents, the spouse, and all members of the household are
considered members of the immediate family.
** “Organization” includes any corporation, partnership,
proprietorship, firm, enterprise, franchise, association, trust,
government agency, or other entity but does not include mutual funds
over which you have no control.



Revised: September 2001                                Policy 11-01-03
                             Conflict of Interest in Research/Teaching


                      ANNUAL DATA SUMMARY REPORT
             STATEMENT OF OUTSIDE INTERESTS AND ACTIVITIES
                            For All Faculty
    (And non-faculty employees responsible for the conduct, design,
                 direction, or reporting of research)
                                   
                        for calendar year 2002


                    School:  ___________________________________


                    Department:  _______________________________


                                   
                                                         
                                                          Number
                                                             
Total number of disclosures submitted (Part I)            ______

                                                             
Number who have had to submit detailed Statements of         
Outside Interests and Activities (Part II)                ______

                                                             
Number who affirmatively answered each of the                
following:

                                                             
Question 1 (Ownership Interests)                          ______

                                                             
Question 2 (Offices and Positions)                        ______

                                                             
Question 3 (Remunerative Activities)                      ______

                                                             
Question 4 (Outside Employment of Students or Staff)      ______

                                                             
Question 5  (Technology Transfer Activities)              ______

                                                             
Question 6 (Other Transactions or Facts)                  ______

                                                             
Number  whose  outside  interests  and  activities  were     
found  to  be  in conflict with their University  and/or     
professional  commitments,  but  which  conflicts   were     
resolved                                                  ______

                                                             
Number  whose  outside  interests  and  activities  were     
found  to  be  in conflict with their University  and/or     
professional commitments, but which conflicts  were  NOT     
resolved                                                  ______



-    Departmental forms should be submitted to the Office of the Dean,
     Director, or Campus President for inclusion in the unit totals.

-    A summary report for the entire unit should be submitted by May
     15 to the Office of the Provost, 826 CL.




Report Prepared By _______________________     Date _______________






               UNIVERSITY OF PITTSBURGH POLICY 11-01-03
               Conflict of Interest - Research/Teaching
    CONFLICT OF INTEREST MANAGEMENT REPORTING FORM – Calendar 2002

This form should be completed by the dean or campus president, as
appropriate, for each faculty or staff member who declared they have
outside interests (i.e. those who gave affirmative answers to
questions in Part I of the Statement of Outside Interests and
Activities Disclosure Form and were required to provide explanatory
information in the Part II Disclosure Form).  This form, along with
copies of the Part II Disclosure Form (and other pertinent documents)
is to be forwarded to the Provost or Senior Vice Chancellor for Health
Sciences as appropriate.


1.   Name of Disclosing Faculty/Staff

     ___________________________________________________


2.   Name of Primary Administrative Reviewer(s) (Department Chair,
     Division Head, etc. if applicable)

     ___________________________________________________


3.   Brief description of the disclosed interest from Part II:

     a. Ownership interest
     
        ___________________________________________________


     b. Offices/Positions
     
        ___________________________________________________


     c. Remunerative Activities
     
        ___________________________________________________


     d. Outside employment of Pitt students or staff
     
        ___________________________________________________


     e. Technology Transfer Activities
     
        ____________________________________________________


     f. Other Transactions or Facts
     
        ___________________________________________________


4.   Do you have interests that may interfere or appear to interfere
     with your ability to provide an unbiased review of this
     faculty/staff member’s disclosure?

       YES  /  NO

       If YES, forward the Part II Disclosure Form and an explanation
       to the Provost/Senior Vice Chancellor for review and action.
       
       
5.   Is simple disclosure alone sufficient to manage the outside
     interest(s)?

       YES   /   NO

       If YES, please briefly explain your thinking.







       If NO, please append a detailed description of the measures
       that were (or will be) taken to successfully manage the
       situation.  Include a description of ongoing follow-up or
       monitoring if appropriate.


6.   Do you consider this case satisfactorily resolved?

       YES   /   NO.

       If NO,  please schedule an appointment with the Provost/Senior
       Vice Chancellor for discussion and further action.



________________________________   ______________ ______________
Signature of Dean/Campus President School/Campus  Date



NOTE: You should inform the faculty that this information will be
      forwarded for review to the Provost or Senior Vice Chancellor
      for Health Sciences as a matter of routine and that it will be
      maintained in a confidential, centralized database.