1. Policy on Harassment –
A. Statement of Purpose –Harassment has become an increasingly prominent national concern in the workplace and in academic institutions. ISMMS regards any behavior that is harassing, discriminatory, or abusive as a violation of the standards of conduct required of all persons associated with the academic mission of the institution. The ideal of American medical, graduate and postgraduate education is to create an environment that nurtures respect and collegiality between educator and student. In the teacher-student relationship, each party has certain legitimate expectations of the other. For example, the learner can expect that the teacher will provide instruction, guidance, inspiration, and leadership in learning. The teacher expects the learner to make an appropriate professional investment of energy and intellect to acquire the knowledge and skills necessary to become an effective physician or scientist. The social relationships required in the achievement of this academic ideal – mentor, peer, professional, staff – require the active trust of partnership, not the dependence of authoritarian dominance and submission.
ISMMS is responsible for providing a work and academic environment free of sexual and other forms of harassment. The institution may pursue any complaint of harassment known to it in order to achieve this goal. A Grievance Committee (the “Committee”) was established in 1992 to serve as an educational resource to the medical school community on issues relevant to harassment and to address complaints of sexual harassment and other forms of harassment and abuse as defined below. Complaints about implementation of school policies concerning appointment, promotion, and distribution of resources, including notification requirements associated with these policies, will not be addressed by this Committee unless they involve, in addition to those complaints, an allegation of harassment or abuse as defined below. The Committee (and an appointed Investigative and Hearing Board (the “Board”) under Paragraph IV.C.2. below, if any) may only consider complaints of harassment and abuse brought by any faculty member, medical or graduate student, house staff or postdoctoral fellow against any other such member of the School community. Complaints by and against other employees of ISMMS will be handled by other appropriate existing grievance mechanisms (e.g., those available through Human Resources). The Committee may act (at the Committee’s discretion) before or after other action(s) an individual may take to exercise his/her rights both within and outside the institution.
The Committee will attempt, whenever possible, to emphasize mediation and conciliation. It will rely on discreet inquiry and trust in dealing with complaints that are brought for its consideration. Confidentiality will be maintained to the maximum extent possible consistent with the need to investigate complaints and with the requirements of the law. Full cooperation with the Committee and an appointed Board, if any, is required of all members of the community.
To ensure an environment in which education, work, research, and discussion are not corrupted by abuse, discrimination and harassment, the following statement has been created to educate members of the academic community about what constitutes harassment and about the mechanism for the receipt, consideration, and resolution of complaints.
Issues also may be brought up during the Steering Committee of the Student Council’s monthly meetings with the Dean, the Dean for Medical Education, the Dean of the Graduate School and the Associate Deans. It must be emphasized that appropriate professional behavior is expected of all members of the School of Medicine and the Hospital. Harassment in any form will not be tolerated.
Consistent with Sections 6432 and 6436 of the New York State Education law, information concerning prevention of sexual assault, domestic violence, stalking, and bias crimes will be provided to all entering students. A Student Safety Committee meets annually with Security to address student safety concerns
B. Definitions of Unacceptable Behavior –
Certain behaviors are inherently destructive to the relationships that are required in a community organized to provide medical and graduate education. Behaviors such as violence, sexual and other harassment, abuses of power and discrimination (based on race, color, religion, national origin, gender, sexual orientation, veteran status, age, disability, citizenship, marital status, genetic predisposition or any other characteristic protected by law) will not be tolerated.
i. Sexual Harassment is defined as unwelcome sexual advances, requests for sexual favors, and/or other verbal or physical conduct of a sexual nature when:
- submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment or academic success.
- submission to or rejection of such conduct by an individual is used as a basis for employment or academic decisions affecting such an individual.
- such conduct has the purpose or effect of unreasonably interfering with an individual’s work or academic performance or creating an intimidating, hostile, or offensive work or academic environment. Sexual harassment is a violation of institutional policy and of city, state and federal laws. Sexual harassment need not be intentional to violate this policy.
Examples of sexual harassment include, but are not limited to:
- sexual assault
- inappropriate sexual advances, propositions or demands
- unwelcome physical contact
- inappropriate persistent public statements or displays of sexually explicit or offensive material which is not legitimately related to employment duties, course content or research
- threats or insinuations, which lead the victim to believe that acceptance or refusal of sexual favors, will affect his/her reputation, education, employment or advancement
- derogatory comments relating to gender or sexual orientation
In general, though not always, sexual harassment occurs in circumstances where the harasser has some form of power or authority over the life of the harassed. As such, sexual harassment does not fall within the range of personal private relationships. Although a variety of consensual sexual relationships are possible between medical supervisors and trainees, such relationships raise ethical concerns because of inherent inequalities in the status and power that supervisors wield in relation to trainees. Despite the consensual nature of the relationship, the potential for sexual exploitation exists. Even if no professional relationship currently exists between a supervisor and a trainee, entering into such a relationship could become problematic in light of the future possibility that the supervisor may unexpectedly assume a position of responsibility for the trainee.
ii. Discrimination is defined as actions on the part of an individual, group or institution that treat another individual or group differently because of race, color, national origin, gender, sexual orientation, religion, veteran status, age, disability, citizenship, marital status, genetic predisposition or any other characteristic protected by law. Discrimination or harassment on the basis of these characteristics violates federal, state, and city laws and is prohibited and covered by this policy.
iii. Abuse is defined, for purposes of this policy, as behavior that is viewed by society and by the academic community as exploitative or punishing without appropriate cause. It is particularly objectionable when it involves the abuse of authority.
Examples of behavior, which may be abusive, include, but are not limited to:
- habitual conduct or speech that creates an intimidating, demeaning, degrading, hostile, or otherwise seriously offensive working or educational environment
- physical punishment
- repeated episodes of verbal punishment (e.g. public humiliation, threats and intimidation)
- removal of privileges without appropriate cause
- grading or evaluations used to punish rather than to evaluate objective performance
- assigning tasks solely for punishment rather than educational purposes
- repeated demands to perform personal services outside job description
- intentional neglect or intentional lack of communication
- requirements of individuals to perform unpleasant tasks that are entirely irrelevant to their education and employment that others are not also asked to perform
Constructive criticism, as part of the learning process, does not constitute harassment. To be most effective, negative feedback should be delivered in a private setting that fosters free discussion and behavioral change.
C. Office of the Ombudsperson –
The Institutional Ombudsman is Barry Stimmel, MD who is available to any student to give counsel and feedback and to discuss informally any situation they have encountered and the nature of any discrimination or abuse, and so forth. This Office is a confidential resource for students except in cases where legal action is needed (e.g., unlawful discrimination or harassment, assault/harm to student or patient).
D. Grievance Committee –
i. PurviewThe Committee is charged with addressing any complaint of harassment or abuse brought by any member of the faculty, medical or graduate student, house staff officer or postdoctoral research fellow against any other such member of the school community.
ii. Composition of the Committee
The Committee will consist of at least 22 members. Among these will be 2 with counseling experience, 2 medical students, 2 graduate students, 2 house staff, 2 faculty with administrative appointments, and 2 research postdoctoral fellows. Faculty members of the Committee will be representative of both basic science and clinical, junior and senior faculty. Every effort will be made to have the Committee reflect the full diversity of the medical school population. The Chairperson of the Committee (the “Chairperson”) shall be a faculty member with experience in counseling and who does not have an administrative appointment. All members of the Committee, including the Chairperson, will be appointed by the Dean after consultation with relevant groups in the School. Faculty will serve staggered 3-year renewable terms; students, postdoctoral fellows and house officers will serve renewable 1-year terms.
E. Grievance Procedures –
i. Any member of the faculty, any medical or graduate student, house officer or postdoctoral research fellow who believes that he or she has been harassed or abused by any other such member of the School community may contact any member of the Committee or the Chairperson to seek advice, or may submit a written complaint to the Committee. The Committee member contacted can discuss the matter with the complainant, advise the complainant of his/her alternatives in pursuing the complaint, including, if the complainant agrees, (and where permitted by law), helping the complainant to resolve the complaint informally without revealing the complainant’s name. Such help may include, but is not limited to, assisting the complainant in drafting a letter to the alleged offender asking that he/she stop the behavior, or coaching the complainant in preparation for a conversation with the alleged offender. The complainant may ask the Committee member to meet directly with the person accused to seek a resolution.If the complaint includes an alleged violation of law, the Committee member initially contacted must bring the complaint to the full Committee, the complaint must be fully documented and investigated, and a report made to the Dean.
ii. Upon request of the complainant to the Committee member originally contacted, or upon receipt of written complaints to the Committee, or when required by law, the complaint, with the names of the complainant, respondent and department withheld, will be discussed by the Committee at its next regular meeting.
iii. Following discussion of the complaint, the Committee has 2 options:
a. It can decide that even if the allegation is true, it does not constitute harassment or abuse. The complainant will be notified of the finding and can be offered guidance and/or assistance in resolving the matter, or be referred to another, more appropriate venue, such as Human Resources, the Faculty Relations Committee or a Tenure Review Committee to pursue the complaint.
b. It can decide that the allegation is sufficiently serious to warrant further investigation. Unless previously submitted, the complainant will be requested to submit a full written account of the complaint. Upon receipt of the written complaint, the Chairperson will appoint a five-member Board and two alternates.
The Chairperson will serve as chair of the Board (or, in case of conflict of interest or other inability to serve, appoint another Committee member) and will appoint at least 4 additional individuals and at least 2 alternates to consider the complaint. Students, postdoctoral fellows, and house staff members are to be excluded from the Board in cases involving a faculty member alleging harassment by another faculty member. In cases involving a student, postdoctoral fellow or house staff (either as an accuser or accused), at least one of the members of the Board will be from the same group. Each Board will have at least one member with experience in counseling, and at least 3 faculty.
iv. Upon selection of the Board, the complainant will be notified of the names of Board members, and will have 48 hours from receipt of such notification to challenge, in writing, any member for cause. The respondent will be notified that a complaint has been brought against him/her, the name of the complainant, the nature of the complaint, and the names of the members of the Board. The respondent shall also have 48 hours from receipt of notification to challenge, in writing, any member of the Board for cause. In the event of a challenge, the Chairperson will decide on the merits and replace Board members if necessary. In the event that the Chairperson is unable to appoint a sufficient number of members not disqualified for cause, the Dean will appoint additional members.
v. Investigative and Hearing Board Procedures.
The preliminary stages of the investigation may consist of meetings of one or more members of the Board with the complainant, respondent and other members of the community who might have relevant information. In the event that preliminary meetings have been held, all information obtained in these meetings will be shared with the entire Board. In all meetings, confidentiality will be stressed.
The respondent will receive the full written complaint with the supporting documentation provided by the complainant to the Board and will be afforded two weeks to provide a written response. This response will be distributed to the Board and provided to the complainant.
The Board will then hold one or more hearings, which the complainant and respondent will attend, either individually or together, along with any other witnesses the Board deems relevant to the complaint. At the hearing, each of the parties may be accompanied by an advisor, who is a member of the Mount Sinai community, but who is not a lawyer, and who will not function as an advocate during the hearing.
At the close of the hearing(s), the Board will deliberate the findings without the presence of either the complainant or the respondent.
Upon concluding its deliberations, the Board will vote on whether or not there has been a violation of this policy based on a majority vote. Recommendations for remedial actions will be discussed. A full report will be drafted, including the findings, vote and recommendations of the majority. It will then be submitted to the Dean.
The Board’s written report will include:
a. a determination that a violation of this policy did or did not take place
b. a listing of its findings of fact
c. a summary of the written submissions of the parties
d. a summary of testimony at the hearing
e. a summary of evidence gathered during the investigation
f. the conclusions it has drawn from this material
g. its recommendations for action to be taken by the Dean.
The Board may recommend sanctions based on the severity of the offense.
Sanctions may include, but are not limited to, verbal reprimand, written reprimand, change in job responsibilities, suspension, discharge, and expulsion.
The Board and/or the Committee may, at their discretion, modify the Grievance Procedures depending on the nature of a particular complaint.
vi. Dean’s Review
The Dean may accept or reject conclusions and/or recommendations of the Board. However, in the event the Dean does not accept either the Board’s conclusions or its recommendations, he/she will meet with the Board to discuss the reasons for the rejection before recording a final decision on the matter.
The Dean will convey his/her decision in writing to the complainant, respondent and the Board.
F. Protection from Retaliation –
All individuals involved in registering a complaint, serving as representatives for the complainant or respondent, as witnesses, or on the Committee will be free from any and all retaliation or reprisal or threats thereof. This principle applies with equal force after a complaint has been adjudicated. Upon submission of a complaint or threat of retaliation, the Committee will review the facts and recommend appropriate action.
G. Re-Evaluation of Procedures –
The Committee will review the grievance procedures periodically. Proposed changes, approved by a majority of the Committee, must be reviewed and approved by the Office of the General Counsel before being implemented.
2. Student Mistreatment Guideline –
Icahn School of Medicine at Mount Sinai is dedicated to providing its students, residents, faculty, staff and patients with an environment of respect, dignity, and support. All members of the Icahn School of Medicine community are responsible for protecting student rights as specified in our Student and Faculty Codes of Conduct, the oaths we take, and institutional policy. Educators (defined broadly to include anyone in a teaching role, including faculty, residents, fellows, nurses, staff, and students) bear significant responsibility in creating and maintaining this atmosphere. As role models and evaluators, educators must practice appropriate professional behavior toward, and in the presence of, students, who are in a particularly vulnerable position due to the formative nature of their status. This guideline, therefore, supplements the institutional policy on harassment and grievances, will assist in developing and maintaining optimal learning environments, and encourages educators and students alike to accept their responsibilities as representatives of Icahn School of Medicine in their interactions with their colleagues, patients, and staff.
Description of Mistreatment
Mistreatment interferes with the learning environment, adversely impacts the student-educator relationship, and has the potential for disrupting patient care and research. Inappropriate and unacceptable behaviors promote an atmosphere in which mistreatment is accepted and perpetuated in medical education and training. While the perception of mistreatment may differ between individuals, examples of mistreatment of students include, but are not limited to:
- Intentional neglect or marginalization (e.g., ignoring, speaking down to, yelling at, ridiculing)
- Insults or inappropriately harsh language in speaking to or about a student
- Berating, belittling, humiliating, or intimidating behavior
- Threat of physical harm or physical punishment (e.g. hitting, slapping, kicking)
- Asking to perform personal services (e.g., shopping, babysitting, picking up food)
- Threat of receiving a poor evaluation/grade for reasons other than course/clerkship performance
- Threat of altering authorship on a publication for reasons other than proper contribution
- Disregard for patient or student safety by requiring a student to perform a procedure or engage in patient care without adequate supervision.
- Sexual harassment, including offensive remarks, being asked to exchange sexual favors for grades or other awards, or being subjected to sexual advances
- Discrimination or harassment based on age, race, color, language, religion, sex, sexual orientation, gender identity or expression, genetic disposition, ethnicity, culture, creed, national origin, citizenship physical or mental disability, socioeconomic status, veteran status, military status, marital status, being the victim of spousal abuse, or based on any other characteristic protected by law.
Such actions are contrary to the good will, trust, and compassion central to the learning culture and working environment in an academic medical center. These actions cannot be tolerated. The sources of mistreatment include, but are not limited to research, preclinical, and clinical faculty, fellows, residents, post-docs, nurses, allied healthcare workers, fellow students and patients.
The Student Mistreatment Resource Panel
I. The School will form a student panel to (1) serve as a sounding board for students with concerns about mistreatment and (2) assist in school-wide education about this topic.
II. Members of the panel will be elected by their peers annually.
III. The Student Mistreatment Resource Panel will be comprised of:
- One (1) medical student at the MS IV level*
- One (1) medical student at the MS III level*
- One (1) medical student at the MS II level*
- One (1) medical student at the MS I level*
- One (1) MD/PhD student*
- Two (2) graduate students*
- One (1) Scholarly Year student, who will act as chair of the Panel*
- Two (2) Faculty Advisors who are the medical school ombudspersons.
*At least one (1) student member of the Panel will also sit on the Grievance Committee.
IV. Panel members will:
- Serve as a sounding board for students with concerns about mistreatment in the educational environment.
- Assist in educating the Icahn School of Medicine community about mistreatment as outlined in the section entitled “Dissemination.”
- Meet with the Dean for Medical Education, Dean of the Graduate School and other medical school leadership on a biannual basis at the end of each semester. At that time, the panel’s de-identified records will be reviewed in order to improve this guideline and/or the program. If the panel or Deans deem it necessary, additional meetings may be scheduled.
- Update this guideline and programming based on the biannual review.
- Sign a statement detailing their understanding of the expectation of confidentiality in dealing with mistreatment related concerns and agreeing to serve on the panel for a one-year term.
- Recognize potential conflicts of interest: if a panel member has a potential conflict of interest that relates to a situation brought before the group (for example, a strong personal relationship with someone involved in the situation) the panel member must recuse himself or herself when the group learns about or discusses the situation. Likewise a student bringing a situation to the panel may request that one of the members not participate if there is a potential conflict of interest. The student should make this request to the chair of the panel or the ombudspersons.
V. One (1) member of the panel will act as secretary and maintain de-identified records which include but are not limited to:
- All mistreatment concerns brought before the panel
- Next steps taken on mistreatment concerns (i.e. sent to Grievance Committee, spoke to Dean, etc.)
All Student Mistreatment Resource Panel records will remain anonymous and only de-identified data will be presented at biannual review meetings.
VI. Student mistreatment concerns will be handled according to the following process:
- Students may report a concern either in person directly to a student member of the panel or by emailing a member of the panel. The panel will meet to discuss the case. Depending upon the severity and complexity of the complaint, the panel may deem it necessary or desirable for the student to meet with the group in order for the panel to ask questions or make suggestions.
- Depending upon the severity or complexity of the mistreatment, or at the request of the affected student, the panel may refer the case to an appropriate group or department at Icahn School of Medicine. When this occurs, the Dean for Medical Education and/or Dean of the Graduate School will also be notified.
At any time during the process, if the panel becomes concerned about an immediate threat to the safety or well-being of the complainant, alleged aggressor, or any person at Icahn School of Medicine or in the community, the panel will notify the Dean for Medical Education and/or Dean of the Graduate School.
To promote a learning environment respectful of all individuals, Icahn School of Medicine will publicize the concern about student mistreatment and this panel’s existence across the institution. Education is a cornerstone in the prevention of student mistreatment. An on-going effort will be made to inform all individuals involved in student education about the appropriate treatment of students and of this guideline. To that end, the following notification mechanisms will be utilized:
- Medical Students: A discussion of mistreatment and our guidelines will occur each year during year, course, and clerkship orientations. Each course and clerkship director will include this guideline in their course and clerkship materials.
- Graduate Students: A discussion of mistreatment and our guidelines will occur during Orientation for first-year students.
- Faculty, Residents and Fellows: This guideline will be sent each year from the Dean’s office to all Course and Clerkship Directors and all MTA directors, who will help disseminate the guideline to those involved in medical student education.
Protection from Retaliation
Retaliation against individuals who bring forward complaints of mistreatment (including but not limited to adverse effects on student evaluation) is strictly prohibited and will not be tolerated.
3. Affirmative Action –
It is the policy of ISMMS that all decisions regarding educational and employment opportunities and performance are made on the basis of merit and without discrimination because of race, gender, color, creed, age, religion, national origin, citizenship, disability, veteran status, marital status, sexual orientation, genetic predisposition, or any other characteristic protected by law. Sexual harassment is defined as a form of sex discrimination and, therefore, any sexual harassment at the school will constitute a violation of the medical school’s nondiscrimination policy.
In keeping with our continuing efforts to achieve a broadening of the representation of women and minority groups throughout the medical school, we have:
- Developed an Affirmative Action Program, which details actions designed to realize the School’s commitment to equal educational and employment opportunities.
- Insured our compliance with Federal, State and Local laws and regulations implementing equal opportunity objectives by meeting the spirit as well as the letter of the law and contractual requirements.
We cannot over-emphasize our commitment to the realization of these goals. Every decision affecting faculty, house staff, fellows, graduate students, employees, and medical students and other members of the medical school community rests solely on demonstrably valid criteria of merit, competence and experience.
Additional information concerning Mount Sinai’s Affirmative Action Program, its interpretation and/or application may be obtained from the Affirmative Action Office located at 1245 Park Avenue, Ground Floor.
4. Alcohol and Drugs –
The following statement describes the Icahn School of Medicine at Mount Sinai’s policy regarding substance abuse for all employees, which include faculty, administration, house staff, students, graduate students, fellows, bargaining and non-bargaining unit employees. The school has a significant interest in ensuring that the educational and work environment is free from the hazards to patients, employees, students, and visitors that are created due to the unauthorized use of alcohol, drugs, or controlled substances.
The illegal sale, manufacture, distribution, or unauthorized use of drugs or controlled substances off-duty whether on or off medical school premises or reporting to classes or clerkships under the influence of un-authorized drugs or controlled substances may constitute grounds for immediate dismissal.
The unauthorized use or possession of alcoholic beverages on medical school premises or reporting to School under the influence of alcohol also may constitute grounds for immediate dismissal.
The school may in its discretion take appropriate disciplinary action up to and including dismissal or termination from employment against anyone who has violated the above rules.
Any employee or student who is suspected of being under the influence of any alcoholic beverage or drug while on duty and who refuses to be medically evaluated or to release the results of such evaluation to the medical school (as employer) or appropriate administrative officer of the School will be relieved from duty and will be subject to disciplinary action up to and including dismissal.
The Drug-Free Workplace Act of 1988 requires ISMMS, as a Federal grant recipient and contractor, to certify that it will provide a drug-free workplace. This is accomplished by providing to each employee or student engaged in a federal grant or contract, a copy of the School’s Drug-Free Workplace policy and statement, and requiring that as a condition of employment under such a grant or contract the employee will:
- Abide by the terms of this Statement; and
- Notify the Director of Human Resources and Labor Relations or his/her designee of any criminal drug statute conviction for a violation occurring in the workplace no later than five (5) days after such conviction.
A Drug-Free Awareness Program has been established to inform all employees about the dangers of drug abuse in the workplace, The School’s policy of maintaining a drug-free workplace, the available drug counseling, rehabilitation and employee assistance programs, and the potential penalties for drug abuse violations.
The Employee Assistance Program (EAP) offers professional guidance counseling and a referral service for substance abuse, as well as other concerns, to students, employees and their immediate families free of charge. For confidential information, contact EAP at (212) 241-8937.
5. Alcohol Policy – Levinson Student Center –
The policy of the School of Medicine regarding alcoholic beverages in the Patricia and Robert Levinson Student Center is to maximize student utilization of the Center while assuring that clear policies are in place. Alcohol is permitted in the Student Center at events sponsored by student organizations or Departments within ISMMS under the following circumstances:
- A student-run organization that is recognized by Student Council is sponsoring the event.
- No student or guest under the age of 21 will be served or permitted to consume any alcoholic beverage.
- Alcoholic beverages are not sold at the event.
- Alcohol must not be taken out of the Student Center into other areas of Mount Sinai.
- Serving alcoholic beverages is always in the context of serving food and non-alcoholic beverages.
- A specific student (or students) is identified as responsible for the event.
- The responsible student will monitor the event so that anyone who is clearly intoxicated is not served any more alcohol.
- If a person has become intoxicated, steps should be taken to try and help the individual sober up prior to leaving the party.
- The responsible student monitoring the event must make certain that any person that has become intoxicated will not be allowed to drive. Cab fare should be provided, if necessary, or an escort should be provided to ensure that the person gets home safely.
- The Administrative Director of Student Affairs is notified in writing about the event at least one week in advance with the clear statement that alcoholic beverages are planned as part of the food and beverage service serving as the application for a permit.
- Funding for alcoholic beverages will not come from tuition resources or the Department of Medical Education budget.
There MUST be a written permission from the Event Coordinator of Student Affairs prior to the event. The person(s) responsible for the event must have the permit with them at the event. The Security Department will be notified that alcohol will be served at the event. Under no other circumstances should alcoholic beverages be used or available in the Levinson Student Center. Please contact the Event Coordinator of Student Affairs with any questions.
6. Drug Testing –
All incoming students are required to undergo drug/alcohol screening. Subsequently, drug/alcohol testing may be requested of any student, at any time, including:
- When concerns about substance use issues arise.
- When any student returns from a leave of any kind.
- When a student self-reports a problem.
- Failure to undergo testing as requested will result in dismissal from the school.
Drug/alcohol testing is conducted both to provide an environment that is safe for our patients and that promotes the highest possible level of learning and professionalism in our students. While ISMMS maintains a drug-free workplace in compliance with federal regulations, it also strives to foster an atmosphere of openness about drug and alcohol related issues. Although people often have strong preconceptions about substance use and drug/alcohol testing, such testing is done out of concern for the well being of our students and of their current and future patients.
7. Family Education Rights and Privacy Act (FERPA) –
The Family Educational Rights and Privacy Act (FERPA) of 1974 and its subsequent amendments afford students certain rights with respect to their educational records. Copies of this Act are available in the Office of the Registrar.
The Family Educational Rights and Privacy Act of 1974 and its subsequent amendments afford students certain rights with respect to their educational records. As detailed below, students have the right to:
- Inspect and review their education records.
- Seek amendment of their education records if they believe them to be inaccurate, misleading, or otherwise in violation of their privacy rights.
- Consent to certain disclosures of personally identifiable information contained in their education records.
- File complaints with the Department of Education concerning any alleged failure to comply with FERPA’s requirements.
All currently registered and former students of Icahn School of Medicine at Mount Sinai have the right to review and inspect their official education records at the School (including, for example, admissions and academic records prepared and maintained by the Registrar) in accordance with these rules. Students who wish to review their records should make an appointment with the Registrar. Access will be granted within 45 days from the receipt of the written request to inspect records.
Students have a right to a response to a reasonable request for explanations and interpretations of the student’s educational records. Students seeking explanations or interpretations of their educational record may make an appointment with the Associate Dean of the Graduate School or Associate Dean for Student Affairs-Medical Education, as appropriate based on the student’s program. If the Associate Dean is unable to provide a satisfactory explanation, the student will be referred to the Dean for Graduate Education or Dean for Medical Education, as appropriate.
Students may not copy records unless the failure to produce copies would prevent the student from exercising his/her right to inspect and review records. A copying fee will be charged.
B. Limitation on Access –
The Act limits a student’s right to access information contained in his/her education records. Accordingly, the School need not permit students to view:
iii. Confidential letters of recommendation placed in the student’s file after January 1, 1975, if:
- The student has waived in a signed writing his/her right to inspect and review those letters (see below); and
- The letters are related to the student’s (i) admission to an educational institution; (ii) application for employment; or (iii) receipt of an honor or honorary recognition.
iv. Records of instructional, administrative and supervisory staff which are in the sole possession of such personnel.
v. Records of professional and paraprofessional personnel which are created, maintained and used solely for the purpose of treatment and are disclosed only to individuals providing the treatment. The student has the right, however, to have such records reviewed by an appropriate professional of his/her choice.
vi. Icahn School of Medicine at Mount Sinai does not require students to waive their right of access to educational records as a condition for admission to the School, for receipt of financial aid or other services or benefits from the School, or for any other purpose. Under certain circumstances, however, a student may wish to waive his/her right of access to confidential letters of recommendation. A student may do so by signing a waiver form. In this event, the student will be notified upon request of the names of persons making such recommendations and the recommendations will be used solely for the purpose for which they are intended. A waiver may be revoked in writing with respect to actions occurring after the revocation. Waiver forms are available in the Registrar’s Office.
C. Amendments and Hearing Rights –
If a student believes that his/her education records contain information that is inaccurate, misleading, or in violation of the student’s rights of privacy, he or she may ask the School to amend the record. Requests for amendments shall be directed to the Registrar, who will respond to the request within a reasonable time. If the request is denied, the student will be notified of his/her right to appeal that decision as specified below.
When the request for an amendment is denied, the student may request a hearing to challenge the content of the record on the grounds that the information contained in the record is inaccurate, misleading or in violation of the student’s privacy rights. Requests for hearing must be submitted in writing to the Associate Dean for Graduate Education or the Associate Dean for Student Affairs – Medical Education (as appropriate) within 10 days of receiving the Registrar’s response denying a request for amendment as discussed above.
D. Hearing –
iv. The decision, which shall include a summary of the evidence presented at the hearing and reasons for the decision, shall be rendered in writing within 15 business-days after the conclusion of the hearing. This hearing will relate only to whether the student’s record is inaccurate, misleading, or otherwise in violation of the privacy of the student, with the decision based solely on evidence presented at this hearing. The hearing cannot determine whether a higher grade should have been assigned.
If it is determined after a hearing that the record in question should be amended, the Registrar will take appropriate steps to amend the record and will so notify the student in writing. If it is determined that the record is not inaccurate, misleading, or otherwise in violation of the student’s privacy rights, the student shall be informed of his/her right to place a statement in the record commenting on the contested information in the record or stating why the student disagrees with the School’s decision not to amend the record. This statement will be maintained as part of the record and will be disclosed whenever the part of the record to which the statement relates is disclosed.
All students have the right to file complaints to the Senior Director of Enrollment Services and Student Information concerning alleged failures by the School to comply with the requirements of the Act.
E. Release of Personally Identifiable Information –
i. Disclosures with consent
- To student shall provide a signed and dated written consent form before the School will disclose personally identifiable information from the student’s educational record. The consent must (i) specify the records that may be disclosed; (ii) state the purpose of the disclosure; and (iii) identify the party or class of parties to whom disclosure may be made.
- When a disclosure with consent is made the School will, upon the student’s request, give him/her a copy of the records disclosed.
ii. Disclosures without consent
The Act permits the School to disclose personally identifiable information from the student’s education records without the student’s consent under any one of the following circumstances:
- To an official or duly constituted committee of Icahn School of Medicine at Mount Sinai that requires access in connection with legitimate educational interests, including, but not limited to matters of financial aid, promotion, or consideration for election to the Lambda Chapter or Alpha Omega Alpha or other honors.
- To officials of another school where the student seeks or intends to enroll. Copies of records will be made available upon request.
- Disclosures in connection with financial aid for which the student has applied or which the student has received, if the information is necessary for such purposes as (i) to determine eligibility or conditions for the aid; (ii) to determine the amount of the aid; or (iii) to enforce terms and conditions of federal, state or private regulations governing such aid.
- Pursuant to a judicial order or valid subpoena. In certain cases specified by law, the School will make a reasonable effort to notify the student of the order or subpoena in advance of the compliance therewith.
- In connection with certain types of litigation between the School and the student.
- To parents of a dependent child as defined by the Internal Revenue Code.
- In a health or safety emergency, where disclosure is necessary to protect the health or safety of the student or other individuals or as otherwise provided by FERPA.
- In a directory, as set forth below.
- To an alleged victim of a crime of violence, where the information disclosed is the final results of School disciplinary proceedings with respect to the crime or offense.
- Disclosure in connection with certain disciplinary proceedings.
- Certain disclosures to parents of a student regarding the student’s violation of any federal, state or local law, or any rule or School policy governing use or possession of alcohol or controlled substances.
- To authorized federal, state or local officials and to accrediting bodies of the School.
The School will maintain a record of each request for access and each disclosure of personally identifiable information from educational records as required by FERPA regulations.
The School will make a reasonable attempt to notify the student of disclosures made pursuant to Section 1(a) and 1(c-l) above. Upon request, the School will give the student a copy of the record disclosed. A student has a right to a hearing to challenge certain disclosures consistent with the procedures outlined above.
F. Directory Information –
The Icahn School of Medicine at Mount Sinai has designated the following information from a student’s education record as “directory information,” which may be disclosed under FERPA without the student’s permission:
- Student Address
- Student Phone Number
- Degree Program(s) & Major Field of Study
- Degree(s) Earned and Date(s)
- Dates of Attendance
- Full-/Part-Time Enrollment Status
- Parent’s Names
- Parent’s Address
- Parent’s Phone Number
- Academic Awards and Honors
- Icahn School of Medicine email address
- Prior Postsecondary Institution(s) Attended
- Photograph/Digitized Image
- Participation in officially recognized Icahn School of Medicine activities
Students’ contact information is included in the student directory and published through BlackBoard.
Preventing Disclosure of Directory Information
The Icahn School of Medicine at Mount Sinai and the Office of the Registrar will exercise discretion in the release of all directory information. In addition, Icahn School of Medicine at Mount Sinai does not release or sell directory information to any outside entity for commercial, marketing or solicitation purposes.
G. Records Kept by the Institution –
i. Admissions Files
- Application form
- Supplemental form
- Letters of Recommendation
- Acceptance Letters
- Medical College Admission Test Scores
ii. Academic Files (Registrar)
- Transcript of grades at Icahn School of Medicine
- Course, clerkship, elective and other evaluations
- Qualifying Exam Outcome
- Thesis Documentation
- National Board Scores
- Shelf Scores
- Dean’s Letter
- Correspondence and internal communications pertaining to academic and other matters.
iii. Financial Aid Records
- FAFSA Forms
- NeedAccess Forms
- Student and Parent(s) Tax and Income Information
- Proof of Citizenship
- Draft Status
- Drug Conviction Information (if any)
iv. Bursar Records
- Record of Receipt of all Loans and Scholarships
- Record of cash paid and date paid
Academic Records are only those that pertain to official files kept in perpetuity in the Office of the Registrar.
H. Information Sharing and Confidentiality –
Icahn School of Medicine recognizes that confidentiality is very important to students. It is a basic right and privilege and we believe that the issue of confidentiality is part of the trust that we expect and value among students, teachers and administrative personnel. The following clarifies the protection of information related to students:
i. Health Information
- All student health information is protected information. There should be no sharing of information except as provided by HIPAA for the care of the student as patient. Teachers, administrative personnel and deans may not receive health information from students’ health care providers except as provided by HIPAA.
- There is certain information that hospitals and health care facilities require as a condition of employment. That information includes PPD, immunizations, and in some cases evidence of toxicology results. Students will be informed that that information is being shared as obtained by Student Health as composite data (we only know who does not comply with completing this information and then would deny clinical privileges but do not know the exact results).
- Toxicology screening is an institutional requirement. Any positive result will be reviewed by senior administrative representatives of the Deans (Graduate School and School of Medicine). The school may require a toxicology screen from any student at any time without need for a stated reason. Failure to comply with toxicology testing in the timeframe required will result in dismissal from school.
- There are times when the Administration may ask a student to comply with an Administrative Psychiatric evaluation. When it is decided that such an evaluation is necessary, the student will be informed and will be apprised of the list of questions that willbe sent to an administrative evaluator (usually a psychiatrist). Students do not have the option to decline such an evaluation when required and would be dismissed from school if they fail to comply. The information referred back to the School will be discussed with the student and will remain in the student’s file which can only be opened by a Dean or his official representative or if requested as a legal document.
ii. Academic Information
Academic information is maintained by the School Registrar.
- Students have access to their academic file for review but will not be given copies of their file.
- The Registrar will not permit dissemination of the file information without the signed consent of a student unless required by law in accordance with FERPA Policy.
- Current teachers and clerkship directors do not have access to the student file, only deans and student affairs personnel in the School of Medicine may access the file.
- Any student wishing to review their file may do so in the presence of the Registrar or Dean’s Designee coordinated through the Registrar.
iii. Other information
If a student seeks counsel from a director, dean, teacher or ombudsman that information should remain confidential between the student and that individual.
A. Any plan to discuss information (e.g., Office of Student Affairs Representative or Program Director with one of the Dean’s) should be with the student’s knowledge and consent.
B. Exceptions to this confidentiality include concerns about the safety of the student, someone related to the student, or the student’s dependent. Safety concerns include suicidal ideation, homicidal ideation, harming another individual substance dependency, behavioral or health concerns that may affect the student or others.
8. Campus-Wide Policies, Regulations, and Requirements –
A. Introduction –In accordance with the requirements of the Education Law of the State of New York, the Trustees of The Icahn School of Medicine at Mount Sinai have adopted rules for the maintenance of order and have established a program for their enforcement:
B. Rules of Conduct –
i. All members of the School community, including faculty, students, organizations, members of the staff of the School, and all visitors and other licensees and invitees, are expected to obey all national, state and local laws.
ii. All members of the School community are prohibited from conduct which is proximate cause of or does unreasonably and unduly impede, obstruct or interfere with the orderly and continuous administration and operation of the School in the use of its facilities and the achievement of its purposes as an educational institution, or in its rights as a campus proprietor. Such conduct shall include, but is not limited to, that which is the actual or proximate cause of any of the following:
- Unreasonable interference with the rights of others;
- Intentional injury to School property;
- Unauthorized occupancy of classrooms, laboratories, libraries, faculty and administrative offices, patient care facilities, auditoriums, public halls and stairways, recreational areas and any other facilities used by the School (unauthorized occupancy being defined as failure to vacate any such facility when duly requested by the Dean, an Associate Dean, Assistant Dean, Hospital Administrator of similar responsibility or chair of a department of the School);
- Malicious use of or intentional damage to personal property, including records, papers and writings of any member of the School community;
- Any action or situation which recklessly or intentionally endangers the mental or physical health or involves the forced consumption of liquor or drugs for the purpose of initiation into or affiliation with any organization
Violations of these policies and regulations by students shall be referred to the Dean of the Graduate School. Students in violation may be expelled in addition to any other criminal or civil penalties. .
Nothing contained in any of the foregoing Rules and Regulations is intended to nor shall it be construed to limit or restrict freedom of speech or of peaceful assembly, or other individual rights guaranteed by the Constitution.
C. Student Behavior –
The administration and faculty of the School are committed to providing a safe and healthy learning environment for all students. Students should conduct themselves appropriately everywhere on the campus of ISMMS, and at affiliated institutions. Appropriate behavior is mandatory when participating in patient care or attending any functions at which patients may be present. In small group seminars, as well as during clinical activities, students are evaluated not only on their fund of knowledge and ability to use this knowledge but also on their responsibility, dependability, reliability, maturity, motivation, attitude, honesty, integrity, and ability to relate and interact effectively with others.
Equally important, however, is the realization that one’s responsibilities do not end with individual behavior but also include not tolerating inappropriate behavior among others. While formal mechanisms, outlined in other sections, exist to provide due process for any specific allegations of inappropriate behavior, general issues should be able to be discussed freely among peers, faculty, and administration. Concerns requiring confidentiality should be discussed with the Dean of Graduate School, individual faculty advisors, or through the School’s Ombudsman Program.
D. Faculty, Staff, and Student Relations –
Just as students are expected to behave in an appropriate and professional manner at all times, so also are faculty, staff, and other employees. Any allegations concerning harassment, abuse, or inappropriate professional behavior should be brought directly to the attention of one of the Associate Deans of the Graduate School or to a member of the Harassment Committee and Grievance Board.
The Executive Faculty has approved the following statement of principles concerning interactions among faculty, house staff, and students.
All interpersonal interactions at ISMMS will be conducted in an atmosphere of respect and concern for the dignity of every individual. Under no circumstances will patients, students, faculty, or staff of Mount Sinai be treated, spoken to, or spoken about in a demeaning manner. Insulting language or behavior must not be tolerated. Faculty, house staff, and students are encouraged to speak up directly and immediately against unacceptable behavior or speech. If a student feels that it would be unwise to pursue such a matter directly, s/he should discuss the issue promptly with an appropriate academic supervisor, administrative supervisor, or dean.
Following are recommendations regarding the implementation of these principles:
i. Chairs of all departments will address these issues at a departmental administrative meeting or grand rounds every year.
ii. Directors of training and course directors are encouraged to discuss (in a non-threatening format), with faculty and house staff, the etiology of inappropriate behavior and engage their collaboration in developing and implementing improvements.
iii. Directors of training and course directors will ask for student evaluations of this aspect of their experience as part of their evaluations with every group of students.
iv. Faculty and house staff will be advised that while appropriate personal behavior is absolutely necessary, it is insufficient. It is also required that inappropriate behavior or language on the part of others must not go without comment.
v. The Dean will issue an advisory regarding this policy to all faculty, house staff, and students. New members of the faculty, house staff and student body will be given copies of this advisory.
vi. The Executive Curriculum Committee will periodically assess students’ experiences to gauge the effectiveness of this initiative.
9. Icahn School of Medicine at Mount Sinai Social Media Guideline –
Social media are internet-based applications, which support and promote the exchange of user-developed content. Some current examples include Facebook, Twitter, Wikipedia, and YouTube. Posting personal images, experiences and information on these kinds of public sites poses a set of unique challenges for all members of the Mount Sinai community, including employees, faculty, house staff, fellows, volunteers and students (collectively “Personnel”). All personnel have responsibility to the institution regardless of where or when they post something that may reflect poorly on Mount Sinai. Mount Sinai is committed to supporting your right to interact knowledgeably and socially; however these electronic interactions have a potential impact on patients, colleagues, Mount Sinai, and future employers’ opinions of you. The principal aim of this Guideline is to identify your responsibilities to Mount Sinai in relation to social media and to help you represent yourself and Mount Sinai in a responsible and professional manner.
The full Guideline may be found in the Faculty Handbook at the following URL:
10. Acceptable Use of Technology Policy –
Acceptable Use of Technology Policy (Updated April 6th, 2015 ) v.3.5
The Icahn School of Medicine at Mount Sinai (ISMMS) expects that all persons who use school computing hardware, software, networking services, or any property related or ancillary to the use of these facilities will abide by the following policy statement:
School information technology resources are provided with the expectation that the school community will use them in a spirit of mutual cooperation. Resources are limited and must be shared. Everyone will benefit if users avoid activities that cause problems for others who use the same system.
Any access to or sharing of protected or confidential information must comply with Mount Sinai Health System policies, including HIPAA, the Family Education Rights and Privacy Act, and the appropriate use of technology guidelines defined in this document. Remember that compliance begins by being aware whether your communication could contain protected or other confidential data and by taking the appropriate steps to secure such content. Your responsibilities within the Mount Sinai Health System extend to a variety of other forms of daily communication, including public areas, telephone use, texting, and social media technologies.
All hardware, software, and related services are supplied by the school for the sole purpose of supplementing and reinforcing the school’s educational, research, and clinical goals as set forth in the student and faculty handbooks and other mission statements of the school. These documents may be found (and not limited to) these locations:
ISMMS medical and graduate student handbooks
ISMMS faculty handbook
HIPAA policies and procedures
Social media guidelines
Use of Hardware and Software
We expect that all students, faculty, and employees will use only the provided hardware, software, or services which they are authorized to use.
All hardware devices using school or hospital email, file, or collaboration services, including personal laptops, must be encrypted, while AirWatch Mobile Device Management (MDM) must be enabled for personal smartphones. Thumb drives or any storage devices that contain protected health information (PHI) or other confidential information must also be encrypted. For more information or support, please contact the Academic IT Support Center (22.214.171.12491, email: ASCIT@mssm.edu).
Individuals may not extend their use of the resources described for any purpose beyond their intended use or beyond those activities sanctioned in school policy statements.
In particular, no one may use hardware and software:
- To acquire personal profit or gain
- To harass, threaten, or otherwise invade the privacy of others
- To initiate or forward email chain letters
- To cause breaches or disruptions of computer, network, or telecommunications systems
- To initiate activities which unduly consume computing or network resources
- To transmit sensitive or proprietary information to unauthorized persons or parties
It is a specific violation of these guidelines to provide account passwords to individuals who are not the owners of the accounts or to obtain passwords to or use others’ accounts.
It is against this policy to copy or reproduce any licensed software or media, except as expressly permitted by the license. Unauthorized use or distribution of software, media, or digital content is a violation of this policy.
Individuals who violate the aims of this policy will be subject to disciplinary action or to referral to law enforcement authorities without prior notification of those who have sent or received such messages. ISMMS IT personnel are authorized to monitor suspected violations and to examine items stored on any school storage medium by individuals suspected of violating this policy.
Web and Data Storage
Access to the Internet is provided as a communications tool and an information resource to facilitate the performance of job- or academic-related functions. This policy applies to any Internet service accessed on or from a Mount Sinai Health System facility, provided by the school, accessed using school-owned equipment, or used in a manner that identifies the individual with the ISMMS or Mount Sinai Health System. The Mount Sinai Health System reserves the right to review any information, files, or communications sent, stored, or received on its computer systems.
Inappropriate use of the Internet may result in loss of access privileges and in disciplinary action up to and including dismissal. Students, faculty, and employees are prohibited from using Mount Sinai Health System-provided Internet services in connection with any of the following activities:
- Engaging in illegal, fraudulent, or malicious conduct
- Working on behalf of organizations without a professional or business affiliation with the Mount Sinai Health System
- Sending, receiving, or storing offensive, obscene, or defamatory materials
- Obtaining unauthorized access to any computer system
- Using another individual’s account or identity without explicit, written authorization
- Attempting to test, circumvent, or defeat the security or crediting systems of the Mount Sinai Health System or any other organization without prior authorization from Information Management Systems and Services/Security and Corporate Data Administration (IMSS/SACDA) or ISMMS IT
- Any use or activity that impedes Mount Sinai Health System operations
Users of school-provided cloud services, such as Google Apps for Education and Box.com, have the ability to share files with colleagues within or outside the Mount Sinai Health System for academic collaboration purposes. Students, faculty, and employees must not, under any circumstances, share unencrypted files containing PHI or other confidential information with colleagues outside the Mount Sinai Health System. As mentioned, compliance begins by being aware of the data that you are generating and by following appropriate steps to secure such content if it contains protected or other confidential information.
Email and Collaboration Technology Usage
Email and collaboration technologies, including Google Apps for Education, are provided to assist and facilitate scholarly communication and collaboration. These technologies are provided for official business and educational use in the course of assigned duties. The school reserves the right to access and disclose all messages sent over its electronic mail systems for the purposes of monitoring security breaches and investigating inappropriate usage as defined in this policy. The Mount Sinai Health System is obligated to comply with legal subpoenas, court orders, and similar lawful requests from external regulators or authorities.
Inappropriate use of email and/or collaboration technology may result in loss of access privileges and disciplinary action up to and including dismissal. Inappropriate use includes but is not limited to:
- Unauthorized attempts to access others’ email accounts
- Transmission of protected and/or confidential information to unauthorized persons or other organizations
- Transmission of obscene or harassing messages to any other individual
- Transmission of offensive material, solicitations, or proselytization for commercial ventures, religious or political causes, or other non-job related solicitations
- Any illegal, unethical, or other activity that could adversely affect the Mount Sinai Health System
Protected Health Information, FERPA, and Other Confidential Information
All hardware devices, including bring your own devices and personal laptops, on which school email, file, or collaboration services are used must be encrypted. AirWatch MDM must be enabled for personal smartphones. Thumb drives or any storage devices that contain PHI data must also be encrypted. For more information or support, please contact the Academic IT Support Center (126.96.36.19991, email: ASCIT@mssm.edu). Students, faculty, and employees are responsible for ensuring that their devices are password enabled and encrypted.
The key points of the above policies are as follows:
- You may use only your ISMMS email account to communicate protected or confidential information. Emails containing PHI, financial information, or other confidential ISMMS information and/or social security numbers may not be sent or redirected to non-ISMMS email accounts.
- The minimum necessary amount of PHI should be disclosed via email. When at all possible, use the Medical Record number, rather than the patient name, as the patient identifier.
- Messages that leave the Mount Sinai Health System network and contain PHI or other confidential information must be encrypted using the ISMMS IT-approved solution described as follows.
- Messages sent within the Mount Sinai Health System network are automatically encrypted.
- Encryption will not prevent misdirection or unintended forwarding of a previous string of emails. Extreme caution must be exercised to prevent such risks. Be aware of the content that you generate.
Secure Messaging and Encryption
In addition to ensuring that your device is encrypted (see above), you must select an email encryption option if you are sending PHI or other confidential information to an external recipient.
Activating the email encryption option:
- For Microsoft Exchange users, include the word [secure] within square brackets in the subject line of the message. The recipient will be asked to self-enroll when the message is opened. The secure send mechanism can be used in any email client (e.g., Outlook, Outlook Web Access, smartphone).
- For Google Apps users, install the Virtru add-on to the browser and/or device (go to http://www.virtru.com for instructions). When composing a message, select the “Virtru Protection is on” option.
Spam and Inappropriate Use of Messaging Tools
ISMMS systems, including email, are intended for official business use. Inappropriate use may result in disciplinary actions and loss of access privileges. Unsolicited mass emailing of materials not related to school business is considered spam and may result in the loss of access privileges.
Student Privacy, Secure Email, and Phishing
Please remember to take care when opening attachments or following links contained in email messages. Verify with the sender of the message if you receive an unexpected attachment or an email that contains suspicious links. Be especially cautious of emails that have been quarantined. Unless a quarantined message is correspondence that you are expecting, do not release the email.
Please also take care with any messages that ask you to provide private information (e.g., birthdays, social security number, credit card numbers, user account passwords). These messages might actually be phishing attempts by persons pretending to be from legitimate companies or organizations. If you have any doubts, contact the party requesting the information for confirmation. Users should not rely on the contact information contained in the email but use the contact information typically found on the company website or on the back of a bank or credit card.
I understand that by receiving ISMMS network and Internet access to email and library resources, I agree to abide by all institutional policies related to use of the ISMMS systems to access the Internet, email, and all other computer and network resources.
I acknowledge receipt of these policies and understand that they might be changed, and I will abide by these changes as reflected on the ISMMS website or received via other forms of communication.
I understand that I am responsible for all actions performed from my computer account. I further understand that, in the course of my work, I may be given or otherwise gain access to confidential or privileged information related to this or other institutions, ISMMS students or employees, or other individuals or groups. I will respect the confidentiality of all information to which I have access and neither divulge information without appropriate consent nor seek to obtain access to confidential information to which I am not entitled.
For more information or support, please contact the Academic IT Support Center (188.8.131.5291, email: ASCIT@mssm.edu)
11. Icahn School of Medicine at Mount Sinai Policy on Business Conflicts of Interest –
Mount Sinai Medical Center has an obligation to ensure that its trustees, faculty, employees and other staff and students adhere to the highest standards of ethical conduct free from any improper external influence or any appearance of impropriety. Situations can occur in which an independent observer might reasonably conclude that the potential for individual or institutional conflict could influence the manner in which individuals carry out their responsibilities or the decisions made by the institution. Even in the absence of an actual conflict of interest, such situations may require actions to minimize the appearance of a conflict.
At the same time, Mount Sinai understands that such individuals and their close family members may have relationships that could raise perceived or actual conflicts of interest, but could benefit Mount Sinai if carefully examined and properly managed.
In order to safeguard the integrity of both Mount Sinai and its constituents, Mount Sinai has adopted a rigorous conflicts policy predicated on full disclosure and appropriate management of any possible conflict of interest. This Policy on Business Conflicts of Interest (the “Policy”) identifies those persons or entities covered by this Policy, sets out the requirements for disclosing potential business conflicts of interest, and specifies the procedures for reviewing such disclosures and determining what measures, if any, should be instituted to manage the conflict.
This Policy is intended to cover conflicts that arise out of business relationships. Mount Sinai has related policies that cover other types of conflicts, such as Mount Sinai’s Policy on Financial Conflicts of Interest in Research and its Policy regarding Financial Relationships with Outside Entities.
12. Student Intellectual Property –
For information pertaining to intellectual property developed by students, please refer to the Mount Sinai Innovation Partners’ website. Specific information can be found in the FAQ section by following the URL below.