Pacific Northwest University of Health Sciences has guidelines to avoid real or potential conflicts of interest. It is your duty as an employee of Pacific Northwest University of Health Sciences to follow the guidelines regarding conflicts of interest. If this is not clear to you or if you have questions about conflicts of interest, contact the Human Resources Department.
What is a conflict of interest (COI)? An actual or potential COI is when you are in a position to influence a decision or have business dealings on behalf of Pacific Northwest University of Health Sciences that might result in a personal gain for you or for one of your relatives. For COI, a relative is any person who is related to you by blood or marriage, or whose relationship with you is similar to being a relative even though they are not related by blood or marriage.
We do not automatically assume that there is a COI if you have a relationship with another university. However, if you have any influence on transactions involving purchases, contracts, or leases, you must tell an officer of Pacific Northwest University of Health Sciences as soon as possible. By telling us that there is the possibility of an actual or potential COI, we can set up safeguards to protect everyone involved.
The possibility for personal gain is not limited to situations where you or your relative has a significant ownership in a firm with which Pacific Northwest University of Health Sciences does business. Personal gains can also result from situations where you or your relative receive a kickback, bribe, substantial gift, or special consideration as a result of a transaction or business dealing involving Pacific Northwest University of Health Sciences. This would also include COI related to research projects.
Additional Conflicts of Interest Related to Financial Aid and Accounting
The university bans revenue-sharing arrangements with any lender. This is defined as any arrangement between a school and a lender that results in the lender paying a fee or other benefit, including a share of the profits, to the school, its officer, employees or agents, as a result of the school recommending the lender to its students or families of those students.
The university bans employees of the financial aid office receiving gifts from any lender, guaranty agency, or loan servicer.
This excludes:
- Brochures or training material related to default aversion or financial literacy.
- Food, training, or informational materials as part of training as long as that training contributes to the professional development of those individuals attending the training.
- Favorable terms and benefits to the student employed by the institution as long as those same terms are provided to all students at the institution.
- Entrance and exit counseling as long as the institution's staff are in control and they do not promote the services of a specific lender.
- Philanthropic contributions from a lender, guaranty agency, or servicer unrelated to education loans.
- State education grants, scholarships, or financial aid funds administered by or on behalf of the State.
The university bans contracting arrangements whereby any employee of the school's financial aid office may not accept any fee, payment, or financial benefit as compensation for any type of consulting arrangement or contract to provide services to or on behalf of a lender relating to education loans.
The university prohibits steering borrowers to particular lenders, or delaying loan certifications. This includes assigning any first-time borrower's loan to a particular lender as part of their award packaging or other methods.
The university prohibits offers of funds for private loans. Schools may not request or accept such offers. This includes any offer of funds for loans to students at the institution, including funds for an opportunity pool loan, in exchange for providing concessions or promises to the lender for a specific number of loans, or inclusion on a preferred lender list.
The university bans staffing assistance from a lender. Schools may not request or accept any assistance with call center staffing or financial aid office staffing. This excludes:
a. Professional development training for financial aid administrators.
b. Providing educational counseling materials, financial literacy materials, or debt management materials to borrowers, provided that such materials disclose to borrowers the identification of any lender that assisted in preparing or providing such materials.
c. Staffing services on a short-term, nonrecurring basis to assist the school with financial aid-related functions during emergencies, including state-declared or federally declared natural disasters, and other localized disasters and emergencies identified by the Secretary.
The university bans advisory board compensation. Employees of the institution may not receive anything of value from a lender, guarantor, or group in exchange for serving in this capacity. They may, however, accept reimbursement for reasonable expenses incurred while serving in this capacity.
Additional Conflicts of Interest Related to Pharmaceuticals or Similarly Related Industry
Gifts: gifts or gratuities offered by industry are prohibited
Meals: meals may be accepted when brought on site for groups to enjoy; however, the representative may not stay for the meal.
Training/Consulting, Travel, and CME: Industry support for travel stipends, educational scholarships, and visiting professorships may only be provided in the form of unrestricted educational grants with monies going directly into an educational account and not directly to specific individuals. Any training activities must be clearly differentiated from sales activities. All content must be controlled by the university.
Samples, Supplies, and Medical Equipment: A written letter of agreement must accompany any such items clarifying the intention of such donation and that no quid quo pro is expected.
Research: Contact the Research Committee and/or the Compliance Officer for possible COI.
The Compliance Officer has oversight over COI and should be consulted when considering accepting industry support of any kind.