Individual Conflict of Interest
Penn State’s Individual Conflict of Interest (COI) Committee and program exist to reduce or eliminating real or perceived financial conflicts of interest investigators may have.
All investigators must disclose Significant Financial Interests (SFI) as defined in policy RP06 to the COI prior to the submission of an application for research funding, at least annually, and within thirty (30) days of the acquisition of a new SFI. An "investigator" is any individual and all faculty who has the ability to make independent decisions related to the design, conduct, or reporting of University Research. Late disclosures may result in a delay in funding, non-compliance determinations, or, if you have PHS funding, a retrospective review of the funded project to determine if bias had occurred.
Disclosures are confidential and will only be shared to the extent necessary to manage any identified conflicts of interest.
Disclosure Process
Investigators should disclose SFI using Penn State’s Conflict Of INterest System, COINS. SFI disclosures are reviewed either administratively or by the Individual COI Committee. In either review process, the reviewers determine whether the SFI constitutes is a real or perceived conflict of interest, and if so, the Committee develops a plan to manage or eliminate the conflict. Read about recommended disclosure language.
The diagram below shows the COI disclosure process. As depicted in the image, after disclosing in COINS, the reported conflict will go through Administrative or Committee Review. Once the review is complete, it will be decided if there is no conflict or if a management plan is needed.
Management Plan
A Management Plan is a set of requirements outlined by the Individual COI Committee and agreed to by the Investigator, which are aimed at promoting transparency in financial relationships, objectivity in research, and protecting human research participants and students. Investigators can provide feedback and request changes to the plan before agreeing to it.
Resources
- Guidelines for Students and Post Docs involved in Faculty Related Significant Financial Interests (pdf)
- Principles for Student and Post Doc Engagement in Faculty Enterprises (pdf)
- Quick Reference for Entrepreneurs (pdf)
- SBIR and STTR: Federal Small Business Awards
- Subcontracting & Conflicts of Interest: For Entrepreneurs (pdf)
- Student Engagement in Entrepreneurial Activities (pdf)
- Recommended Disclosure Language
Standard Operating Procedures
- Administrative Review and Processing of COI Disclosures
- Handling of Noncompliance
- Handling of Disclosures of SFI and COI Related to PHS-Sponsored Research
Committee Membership
The Individual COI Committee is comprised of faculty from at least two of the following disciplines:
- Agricultural Sciences
- Earth and Mineral Sciences
- Engineering
- Health and Human Development
- Science
One faculty from the social sciences/humanities and one active human participants investigator are also on the committee.
Individual COI Meeting Schedule
| Disclosure Forms must be submitted by 4:00 pm on: |
Meeting Dates (called to order at 9:30 am) |
|---|---|
| August 10, 2022 | August 19, 2022 |
| September 7, 2022 | September 16, 2022 |
| October 12, 2022 | October 21, 2022 |
| November 9, 2022 | November 18, 2022 |
| December 7, 2022 | December 16, 2022 |
PLEASE NOTE: Due to the confidential nature of the information discussed, Committee meetings are not open to the public. Meetings may be canceled if there is not a quorum or if no new disclosures were received.
If you have questions about individual COI and COI disclosure, please email coinsadmin@psu.edu or call 865-1775. Investigators whose primary affiliation is with the College of Medicine should go to the COM Conflict of Interest website.