Faculty Disclosures: Additional Guidance and Examples for Policies AC80 and RP06

Guidance:

• Preparing scholarly publications, such as textbooks, conference proceedings, and publications in academic or peer reviewed journals are considered to be "scholarly activities" and do not require preapproval or disclosure under Policy AC80. NOTE: The financial interest may need disclosed under Policy RP06 if thresholds apply.
• However, writing an article for a consumer magazine (entertainment, sports, general interest, news, etc.) is not a "scholarly activity" and will need disclosure under Policy AC80. In addition, the financial interest may need disclosed in COINS under Policy RP06 if thresholds apply.

Examples:

• You are teaching a 3-week professional development course during the Fall semester at a government agency. Conducting short courses including non-credit or professional courses does not require prior approval. However, this will requires disclosure per policy AC80.
• NOTE: This does not need to be disclosed in COINS under RP06 because it is income from a teaching engagement sponsored by a U.S. government agency.

Examples:

• You are writing a paper with a colleague from another university. There is no contract, compensation, agreement, or required time commitment. This is scholarly collaboration and does not require disclosure under AC80 or RP06.
• You are conducting general fundamental research with a colleague at another institution. There is no contract, compensation, agreement, or required time commitment. This is scholarly collaboration and does not require disclosure under AC80 or RP06.

NOTE: Any research that is a sponsored award at Penn State, even if there are other collaborators from other Universities, does not require disclosure under AC80 or RP06.

Examples:

• You have been named on a grant at another university or are receiving compensation to do research at another entity outside of Penn State (or possibly at a company that is the recipient of federal funding). However, because this is not a Penn State research project, it is considered an outside professional activity and requires prior approval and disclosure under AC80. The activity will also need disclosed in COINS under RP06 if related to your institutional responsibilities and if thresholds apply.

NOTE: Receiving salary support on a grant that has been awarded through Penn State is not considered compensation.

• You are conducting research at another university in your area of expertise. You are not receiving compensation, and there is no formal contract or agreement. However, you have agreed to dedicate a certain number of hours per week to the project, or you have agreed to work on the project for a certain amount of time, such as six months. Because there is a required time commitment, this activity would need prior approval and disclosure under AC80 and disclosed in COINS under RP06, if thresholds applied.

Examples:

You have decided to start your own company. Prior to filing the paperwork, you must request prior approval per policy AC80. Even though your company has yet to make any money, you must also update your disclosure in COINS. Once your company is created, you must disclose the time spent on company activities per policy AC80.

Examples:

You received compensation to consult with an outside entity, such as serving on a company's Scientific Advisory Board. This does not require prior approval per policy AC80. However, this does require disclosure per policy AC80, and the compensation from the consulting must be disclosed in COINS per policy RP06, if thresholds apply.

Examples:

• You obtain a patent after the University declined to pursue a patent for an invention you created during the course of your employment. You then license this technology to a company. This does not require prior approval or disclosure per AC80 because it is not Penn State IP, but will need disclosed in COINS per policy RP06 upon receipt of royalties.
• You are writing a textbook that will be copyrighted by the publisher. This is not conveying IP rights to another entity and does not need prior approval or disclosure under policy AC80.
• You are considering signing a consulting agreement with a private company, or a foreign university. The agreement asks you to assign all IP developed during the course of your consulting to that company/university. You must obtain prior approval through the AC80 process, which includes review and approval/denial by the Office of Technology Management.

Guidance

• Holding any position or professional appointment at another university requires prior approval and disclosure under policy AC80. This includes, but is not limited to positions such as visiting adjunct, lecturer, research assistant professor, teaching professor, scientist, fellow, research associate, etc. If thresholds apply, this will also need disclosed in COINS under policy RP06.
• NOTE: Full-time faculty are not permitted to hold tenure at another institution.

Examples:

• You own a company and want to hire some of your students to provide them with real world experience. Involving undergraduate or graduate students in your company requires disclosure and prior approval per policy AC80. NOTE: If your company is related to your University responsibilities or expertise, you must disclose in COINS per RP06.
• You are working on a research project that is a sponsored award to Penn State. You have graduate students working on the project as well. Involving students does not need prior approval or disclosure under either AC80 or RP06 since this is a research project through the University.
• You are working on a research project that is a sponsored award to Penn State. You have graduate students working on the project as well. At the same time, you are serving as a consultant for a private company whose products or services are related to your research at the University. As long as your students are ONLY working on University research and are not involved in your consulting activities, the student involvement does not need prior approval or disclosure under AC80. NOTE: Your private consulting may need disclosed in COINS under policy RP06 if thresholds apply.
• You own a company and want to provide internships to your students. As long as you set up the internship with the University, this does not need prior approval or disclosure under AC80 since you have gone through the proper channels to set up the internship. NOTE: If your company is related to your University research, you must disclose in COINS per RP06.