Department of Health and Human Services
Office of the Director
Office of Extramural Research
Building 1, Room 144
Bethesda, MD 20892
Phone: (301) 496-1096
Fax: (301) 402-3469
Oct. 18, 1999
To: Extramural Staff
From: Deputy Director for Extramural Research
Subject: Policy Announcement 1999-02: Blanket waiver of conflict of interest for peer review consultants from multi-component institutions
Background: In the past, the requirements of the conflict of interest statutes and regulations that apply to Federal employees have been applied to peer review consultants (e.g., study section members) who are not Federal employees. Under those statutes and regulations, a conflict exists if the employee's duties would have an effect on the financial interests of an organization with which the employee has certain affiliations. The term "organization" encompasses all campuses of multi-campus institutions, except for subsystems within 22 states, specified in the Federal Register, Vol. 51, No. 80, p. 15626, April 25, 1986, which are considered separate entities, not part of a single organization, for purposes of determining whether a conflict of interest exists.
Policy Statement: Henceforth, for peer review consultants who are not Federal employees, all separate organizational components/schools of multi-component academic institutions, hospitals, health centers, and research institutes may be considered sufficiently independent such that an employee of one component can review an application/proposal from another component without a conflict of interest, so long as any other real or apparent conflict of interest is resolved. In practice, for example, this means that
(1) the separate campuses of the California State system are considered separate components in the same way that the separate campuses of the University of California system are so noted in the Federal Register citation above;
(2) the separate campuses of the Harvard system are considered separate components;
(3) the Johns Hopkins Bayview Medical Center and the School of Arts and Sciences, Homewood Campus, are separate components;
(4) the Johns Hopkins Schools of Arts and Sciences and of Engineering, Homewood Campus, are separate components;
(5) for purposes of this blanket waiver, the Departments of Biology and Chemistry within the School of Arts and Sciences are NOT separate components.
In the future, other blanket waivers may be established; in the interim and subsequently, other waivers may still be granted on a case-by-case basis.
Wendy Baldwin, Ph.D.
Issuing Office: OER/OEP (301) 435-2690