Financial Conflict of Interest in Research

The purpose of this policy is to promote the highest ethical standards in situations where conflicts of interest may occur in the conduct of research.

Campus Access

The university reserves the right to restrict or prohibit access to university property and to prohibit certain activities on campus.

Biorepositories

USC encourages the creation of repositories (sometimes called biorepositories, registries, banks, or libraries) that provide access, for use in future research, to data and human biospecimens.

Reporting Wrongdoing

USC requires faculty, staff, students, volunteers and others affiliated with the university to report suspicion of wrongdoing promptly to the proper authorities for investigation.

Designating Honorary Alumni

On occasion the university, the Alumni Association, or the dean of an academic unit wishes to acknowledge the extraordinary service or merit of an individual who has neither an earned degree from USC nor qualifies for an honorary degree.

Independent Contractors

The Internal Revenue Service requires the university to properly classify independent contractors. This policy and the accompanying independent contractor website (see below for link) identify the steps, documents and processes necessary to ensure proper classification of and subsequent payment to independent contractors.

Accounting and Auditing Complaint Reporting

In order to adhere to the highest standards of integrity, the university encourages employees to submit complaints regarding accounting, internal accounting controls, or auditing matters or concerns (“Accounting Matters”).

Providing Employment References

The university operates as a single employer and has the right and responsibility to share among university departments accurate employment information concerning the job history and performance of current or former staff employees.

Hiring Foreign Nationals and Immigration Employment Sponsorship

The process of employing foreign nationals (as faculty, staff, or employees claiming student status) involves federal rules and regulations that, if not carefully followed, can result in severe penalties to both employee and employer.

HIPAA CLIN-201 Use of Protected Health Information for Treatment Payment and Health Care Operations

University of Southern California (USC) is permitted to use and disclose an individual’s Protected Health Information for treatment, payment and health care operations, provided: USC gives patients a Notice of Privacy Practices (Notice), which
describes the ways in which USC may use patients’ PHI; USC makes a good faith effort to obtain written acknowledgement of receipt of the Notice; and USC only uses and releases the minimum amount of health information necessary when doing so for payment or healthcare operations purposes.

HIPAA BUS-701: Policy Regarding Business Associates

The University of Southern California (USC) ensures that its business associates protect patients’ right to privacy consistent with USC’s obligations under federal and state law and USC’s privacy policies.

HIPAA CLIN-204 Facility Directory

Purpose is to ensure that the maintenance of the facility directory at University of Southern California is in accordance with the HIPAA privacy regulations.

HIPAA CLIN-200 Notice of Privacy Practices

The University of Southern California (USC) is required to give all patients a Notice of Privacy Practices (Notice), which explains i) the ways that USC may use and release their health information; and ii) describes the patients’ rights with respect to their health information.

HIPAA GEN-105 Disclosures of De-identified Information

The University of Southern California (USC) may use or disclose de-identified health information without obtaining a patient’s authorization.

HIPAA GEN-103 Public Policy Disclosures

USC may use or disclose PHI for treatment, payment and health care operations without an individual’s authorization in accordance with USC HIPAA Policy CLIN – 201 and USC’s Notice of Privacy Practices, provided the individual has acknowledged receipt of USC’s Notice of Privacy Practices or USC has made good faith efforts to obtain the individual’s acknowledgement of receipt.

HIPAA GEN-102 When to Obtain Authorizations

The University of Southern California (USC) may use and disclose an individual’s Protected Health Information (PHI) only pursuant to a written Authorization of the
patient or the patient’s Personal Representative with the following exceptions.

Recharge Centers

USC schools, academic departments and other university divisions (units) may establish a recharge center (RC) to provide goods and/or services to university activities, programs and organizations.

University Signature

This policy identifies who is authorized to enter into Agreements on behalf of the University and how authorized individuals may delegate signature authority. This policy also outlines conditions that must be met before any Agreement on behalf of the University is signed and the use of electronic signatures.

Employee Definitions

There are two classifications of employees: non-exempt and exempt. All employees are classified as non-exempt unless the duties performed meet criteria established under federal and state regulations that would allow the employee to be classified as exempt.

Student Records

The University of Southern California maintains the privacy of student education records and allows students the right to inspect their education records consistent with the requirements of the Family Educational Rights and Privacy Act of 1974 (FERPA).

Relationships with Industry

The purpose of this policy is to: Support USC’s standard of maintaining a culture of ethics in its business relations and to minimize conflicts of interest and the appearance of impropriety in our relationships with pharmaceutical companies, biotechnology companies, device and medical equipment manufacturers and other healthcare suppliers (“Industry”).

Institutional Conflict of Interest in Research

The objective of this policy is to promote the highest ethical standards in the conduct of research in situations where institutional conflicts of interest (“ICOI”) may occur, and to determine those instances when an ICOI is unacceptable.

Joint Ventures

The objective of this policy is to protect the university’s tax-exempt status in situations in which the university may enter into a joint venture with one or more parties that are not exempt from federal income taxation.

Affiliated Organizations

Consistent with its tax-exempt purposes, the university may, from time to time, establish affiliates that operate as separate organizations.

Individual Development Plans for Faculty

Individual Development Plans may be considered at the suggestion of either the individual or the chair or dean, for those faculty who would benefit from such plans.

Records Management

All units of the university are responsible for ensuring appropriate use, retention and destruction of university records by establishing and following record management practices consistent with this policy.

Galen Event Booking

As the managing unit for the USC Galen Center, the Athletic Department works with the university community, our neighbors, and local and national entertainment organizations to insure the booking of quality and appropriate events in the center.

Space Planning and Management

USC’s physical facilities, like its personnel and financial assets, are resources to be planned, managed and maintained in a manner which most contributes to the university’s dual missions of research and instruction.

Misappropriation of University Assets

It is the responsibility of every university employee, regardless of rank or job title, to safeguard university assets and to report any suspected misappropriation of university assets.

Fitness-for-Duty Evaluation

Staff are expected to manage their health in such a way that they can safely and effectively perform their essential job functions and to discuss with their supervisor any circumstances that may impact their ability to do so.

Pets on University Property

The intent of this policy is to maintain the university as a productive, safe, and clean environment in which to study, conduct research, work and visit.

School and Department Commitments

Many schools make commitments with their chairs or department/division directors which are incorporated in the operating budget.