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National news recently exposed the failure to disclose relationships with industry by a prominent oncologist Dr. Jose Baselga, who was until recently the Chief Medical Officer for Memorial Sloan Kettering Cancer Center.  The article was jointly reported by ProPublica and the New York Times after conducting a simple search of the Center for Medicare and Medcaid Services (CMS) Open Payments database and comparing payments made to the physician with disclosures of financial interests in articles he authored. The review is similar to the method used in a recent research letter published in JAMA Oncology that found that 32% of authors on papers reporting results from clinical trials of drugs later approved by the FDA “did not fully disclose their payments from the trial sponsor.”

These situations and their consequences remind us of the importance of transparency in maintaining public trust.  The University also conducts a review of the data in open payments in comparison with disclosures reported on the Report of Non-University Activities (RNUA).  We identify financial interests that meet significance thresholds related to a university research project.  Significant financial interests reasonably related to university research require management plans, including the requirement to disclose the interest in publications and presentations and requiring manuscripts undergo an impartial review process to ensure that adequate conflict of interest disclosures have been made to the journal.

Researchers must take the steps to ensure they are making full disclosures of financial interests and industry relationships to the University, the journals and also in other writing, speaking and teaching situations.  This includes grant applications.

Transparency begins with disclosure.  Here are some steps to take:

  • [Physician Faculty] Review the data about you published in the Open Payments website. It is your obligation to ensure its accuracy as well as consistency with complete disclosures in all aspects of your professional responsibilities. Open Payments database
  • [Physicians, Non-Physician Faculty, and all academic professionals] Disclose non-University activities on the Report of Non-University Activities (RNUA) at START myDisclosures.
    • The deadline to submit a disclosure for the annual process is October 8, 2018.
    • Update your RNUA disclosure throughout the year when your activities change.
  • Discuss your non-University activities with your Unit Executive Officer.
  • Contact the University Conflict of Interest Office to provide you with university policy and guidance as well as assist you with creating a management plan.


Jacquelyn Jancius

Director, Conflict of Interest


Joanna Groden, PhD

Vice Chancellor for Research


Office of Vice Chancellor for Research

Conflict of Interest Office or (312) 996-3642


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