Consulting by Dually-Appointed and UPMC-Only Employees

Personnel dually employed by the University of Pittsburgh and UPMC or University of Pittsburgh Physicians (UPP), as well as employees with a UPMC-only appointment, must have all consulting contracts reviewed and approved by the UPMC Office of Ethics, Compliance and Audit Services.  

All agreements and related correspondence must first be submitted to UPMC Conflict of Interest staff via email.

Following UPMC approval, UPMC personnel will automatically forward the consulting contract to the University of Pittsburgh COI Office for additional reviews which may be required.

Additional instructions on this review and approval process, as well as related deadlines, are available on UPMC Infonet.  Policies are contained in the University and UPMC's joint policy on industry interactions, known as the Industry Relationships Policy (IRP), UPMC Policy HS-EC1702

Outside Activity & Consulting Contract Approval Process under the IRP for University Faculty in the Schools of the Health Sciences (SOHS) with a UPMC/UPP Appointment (PDF) »

Special Circumstances

Public Health Service (PHS) Funded Investigators

Personnel engaged in research that is funded by an agency of the Public Health Service (PHS) are subject to a review conducted by the University, pursuant to federal regulation, to determine if any financial interests are related to and create a Financial Conflict of Interest (FCOI) with PHS-funded activities. If expected remuneration may exceed $5,000 in any 12-month period, a “PHS COI review” is required. 

However, the following process applies after the UPMC Office of Ethics, Compliance and Audit Services has completed its review:

  • If remuneration will not exceed $10,000 in a 12-month period, then the responsibility for this review rests with the faculty or staff member's specific department.

    Department-level Public Health Service (PHS) COI Review of Consulting Agreements (PDF) »
     
  • If remuneration will exceed $10,000 in 12-months OR compensation includes an ownership interest of any amount in a nonpublic company, then the University’s Conflict of Interest Committee (COIC) will make the final FCOI determination with input from the respective department chairperson. The COI Office will facilitate reviews for which the COIC is responsible.

Disclaimer

Questions regarding terms of a consulting agreement that are not related to University or UPMC compliance should be addressed by a personal attorney.  Consulting agreements are reviewed solely for the purposes of compliance with applicable UPMC and/or University of Pittsburgh policies.  No legal review or analysis is performed by the University or UPMC for any other purpose. 

All UPMC and University of Pittsburgh personnel are responsible for ensuring that all outside consulting activities are compliant with applicable institutional policies.

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