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Memorandum on Policy Proposal for Management of Conflict of Interest

The following memorandum was sent to all NIH staff on September 24, 2004, to notify them of the agency’s plan to seek a one year moratorium on consulting with pharmaceutical and biotechnology companies. This step was taken to allow the agency adequate time to expand NIH’s system of oversight for outside activities.

MEMORANDUM

September 24, 2004

Topic: Policy Proposal for Management of Conflict of Interest

On June 22, 2004, Dr. Zerhouni outlined to Congress a set of proposed policies to revamp the NIH Ethics Program. One component of activities at NIH that received intense scrutiny from the public and Congress is consultation agreements between NIH employees and pharmaceutical and biotechnology companies. During the June 22 hearing, Congress informed us that they had identified a number of these outside activities with industry by NIH employees that were not in the NIH data of approved activities previously provided to them.

Although NIH has not completed our review and analysis of individual consulting activities, we have identified vulnerabilities in our system that give us pause. It is clear to us that if these activities are to continue, we will need a substantially expanded system of oversight to assure Congress and the public that conflicts of interest are prevented.

To this end, in addition to pursuing a permanent ban for all senior NIH staff on consulting with pharmaceutical and biotechnology companies, we will now seek a one year moratorium on such activities for all NIH employees.

To be clear, we still value interactions between NIH staff and industry. During the period of the proposed moratorium, as appropriate, interactions with industry will continue as official duty activities. The moratorium will give us time to complete our review of specific cases, develop effective information systems to track outside activities, and develop more effective ethics training programs for staff before a final policy is put in place.

This action is being taken to ensure that NIH retains full public confidence in its research. Although this has been a difficult decision, I along with the leadership of NIH believe that it is in the best interest of the NIH.

This page last reviewed on March 3, 2011

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