BACKGROUND
‘Current USC Policy evolved over a five year period in response to Federal regulatory policy (1990-95)
lPublic Health Service (PHS) – Objectivity in Research
lNational Science Foundation (NSF) – Financial Disclosure Policy
lFinal Rule Issued – July 11, 1995
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No official policy at USC prior to 1994 (AAU Guidance used as reference)

Catalyst for creating policy was proposed federal regulations with PHS first proposed rule in 1989: revised in ’91

NSF followed with proposed rule in 1992

Initially many differences in policies

Under pressure from Universities – agencies worked together and produced final rules that were similar w/ few small differences

Jointly published Final Rule in July of 1995

Note: That neither is call “Conflict of Interest Policy”

USC endured a grueling process to develop its current policy
•1990 Committee appointed by Provost
•18 months later – final draft sent to Faculty Senate (rejected in spring of ’92)
•Second committee formed in Fall of ’92
•Policy signed by President – April ‘94