General Policy

A.  Each NYULMC Member has a responsibility to conduct his or her Medical Center duties and the affairs of the Medical Center in a manner that promotes the best interests of the organization. 

B.   A Conflict of Interest may exist whenever an NYULMC Member participates, directly or indirectly, in the selection, award or administration of any business transaction which involves the Medical Center and the NYULMC Member, his or her Immediate Family, or an entity in which he or she has a Financial Interest.  Employment agreements between the Medical Center and the NYULMC Member are not business transactions giving rise to Conflicts of Interest under this Policy.  Examples of Business Conflicts of Interest

C.   The Medical Center does not engage in any matter giving rise to a potential Conflict of Interest involving an NYULMC Member unless the matter has been fully disclosed and evaluated in accordance with this Policy and a plan for managing or eliminating the Conflict of Interest has been adopted.

How & When to Disclose

The Annual Disclosure Form must be submitted by the following NYULMC Members to the Conflicts Management Unit (CMU) upon appointment, annually therafter, whenever a specific situation gives rise to a potential Conflict of Interest, or when requested by the CMU:

• Chairs, Vice-Chairs, Department Administrators, and all employees and officers at the level of Vice-President, Assistant Dean, Director or above;
• paid full and part-time faculty members;
• investigators participating in the Medical Center's research or sponsored programs;
• persons with purchasing authority; and
• Oversight Committee Members (e.g., the Pharmacy and Therapeutic Committee (PNT) and the Institutional Review Board (IRB)).

The Annual Disclosure Form must be completed and returned within thirty (30) days of receipt from the CMU.  See the Policies on Conflicts of Interest, Commitment and Consulting for more details about the disclosure process.  

Confidentiality.  Disclosures will be kept confidential and divulged by the Medical Center for review under the Policies on Conflicts of Interest, Commitment and Consulting on a need-to-know basis only.

Review & Evaluation Process

The Conflicts Management Unit will conduct an inital review of the disclosure forms to determine if a potential Conflict of Interest (COI) exists.  Matters where a potential COI exists will be submitted to the Business Conflict of Interest Committee (BCOIC) for further review, with the exception of matters involving a Corporate Officer.  Those matters will be submitted to the Audit & Compliance Committee of the Board of Trustees (Audit & Compliance Committee). 

The Medical Center will not approve a business COI matter involving a non-Corporate NYULMC Member unless the BCOIC finds that there are extraordinary circumstances that merit an exception, in which case a plan for managing and monitoring the COI will be implemented. For conflict matters involving Corporate Officers, the Audit & Compliance Committee shall determine if extraordinary circumstances exist to merit an exception for managing and monitoring the conflict.

When to Recuse Yourself

A NYULMC Member must recuse himself or herself from any matter that involves his or her participation, directly or indirectly, in the selection, award or administration of that matter.  The NYULMC Member must also notify the Conflicts Management Unit of the recusal.

Business COI Terms

See our Glossary for the following Business COI Terms: 

Conflict of Interest; Consulting Compensation; Corporate Officer;

Financial Interest; Immediate Family; NYULMC Member;

Outside Position; Ownership Interests; Royalty Income

 

Examples of Buiness Affairs COIs

See our Business COI Examples for further clarification of Conflicts of Interest involving Business Affairs.

Enforcement for Violating Policy

Violations of this Policy are subject to disciplinary action, up to and including termination of employment or association with the Medical Center.  Committee Members who fail to disclose as required by this Policy will be placed on suspension or removed from the committee.  

Questions

For further guidance on this Policy see our FAQs on Business conflicts.  You may also contact the Conflicts Management Unit.

Relationship to Other Policies

This Policy and the Policy on Trustee Conflicts of Interest replace the Medical Center's Conflict of Interest Policy dated March 18, 2004 and supplements, not replaces, other Medical Center policies including the guidelines listed in the NYU Faculty Handbook. 

Matters involving an NYULMC's Member participation in research are reviewed under the Medical Center's Policy on Conflicts of Interest in Research and Sponsored Programs.