Approval by Department
To ensure that outside relationships do not negatively impact a faculty or staff member’s performance of his or her University duties and that any conflicts of interest (COIs) created by such activities are identified and appropriately managed, the University requires faculty and staff to seek the prospective approval of their supervisors.
All personnel seeking to engage in a consulting relationship should first inquire with his or her specific department, division, or center to learn of any unit-specific requirements for seeking approval of outside activities. Additional review and approval may be required, depending on your circumstances.
Personnel employed only by the University of Pittsburgh with no UPMC or University of Pittsburgh Physicians (UPP) appointments are not required to submit consulting contracts to the University’s COI Office for compliance review. However, the COI Office is available to assist with ensuring that terms of an agreement do not conflict with University policies or the Industry Relationships Policy (IRP), which applies to faculty, staff, and students in the Schools of the Health Sciences.
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:
- 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.
Schools of the Health Sciences Industry Relationships Policy
Faculty, staff, and students in the Schools of the Health Sciences (SOHS) are subject to the requirements of the Industry Relationships Policy (IRP), which governs interactions between personnel and students in the SOHS and representatives of the pharmaceutical, biotechnology, medical device, and hospital equipment supply industry. This policy places additional restrictions on consulting relationships and attendance at industry events.
If remuneration will exceed $10,000 in 12-months OR compensation includes an ownership interest of any amount in a nonpublic company, the following approval process is required, which varies by school and/or department.
Questions regarding terms of a consulting agreement that are not related to University compliance should be addressed by a personal attorney. No legal review or analysis is performed by the University for any purpose.
All University of Pittsburgh personnel are responsible for ensuring that all outside consulting activities are compliant with applicable institutional policies.
Please contact the University of Pittsburgh COI Office by email or call (412) 383-1021.
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