Individual Conflict of Interest

What is a Conflict of Interest?

Penn State’s Individual Conflict of Interest (COI) Committee and program exist to reduce or eliminate real or perceived financial conflicts of interest investigators may have. A conflict of interest in research can occur when an investigator is in a position of influence on a research project, and their financial interests outside of the University are such that they or their family members could potentially benefit from the outcome of the research.  NOTE: Investigators whose primary affiliation is with the College of Medicine should visit the College of Medicine's Conflict of Interest website.

An "investigator" is any individual, regardless of their title or position, whether faculty, staff, or student, who can make independent decisions related to the design, conduct or reporting of University Research, but not including individuals who perform only incidental or isolated tasks related to a University Research project. 

Why Is Disclosure Important?

The University’s policies are intended to foster interactions between the private sector and academia while protecting against any risks to research integrity by reducing or eliminating real or perceived financial conflicts of interest. The University requires all investigators to disclose significant financial interests (SFI) as defined by policy RP06 in order to:

  • Comply with federal regulations. Most federal sponsors require researchers to disclose any significant financial interests, including those held by a spouse or dependent children, that reasonably appear to be related to the researcher’s institutional responsibilities. 
  • Prevent potential bias in study design, data collection and reporting.
  • Maintain objectivity and integrity of research. 


Where to Disclose

All financial disclosures are made in Penn State’s Conflict Of INterest System, COINS. Disclosures are confidential and will only be shared to the extent necessary to manage any identified conflicts of interest. NOTE: AC80 Pre-approvals and disclosures are not submitted in COINS but are submitted using the appropriate forms. See the Conflict of Commitment webpage for more information and to access the pre-approval and disclosure forms.


Who Must Disclose

All tenure-line faculty members and many research personnel are required to make an annual disclosure regardless of if they conduct research or have a conflict.



When to Disclose

  • Annually
  • Within 30 days of acquiring a new SFI
  • Prior to the submission of an application for research funding (if disclosure is not up to date)

Late disclosures may result in a delay in funding or non-compliance determinations. If you have Public Health Service (PHS) funding, a late disclosure may result in a retrospective review of the funded project to determine if bias had occurred. 



Researchers conducting human subjects research are responsible for protecting the welfare and the rights of the research participants. Therefore, conflicts of interest are a special concern in human subjects research. If a researcher has a significant financial interest in a company sponsoring or benefiting from the research, this could potentially raise questions about research objectivity. Research studies in which a member of the study staff has a financial interest as defined by policy RP06 must be reviewed by the Conflict of Interest Review Committee (CIRC -HY) or Conflict of Interest Committee (COI – UP). IRB approval will not be granted until the IRB has reviewed the recommended management plan.

Once disclosed in COINS, your disclosure will be administratively reviewed by the COI program. If no conflict is found, then no further action is required from you after disclosure. If there is a potential conflict, your disclosure will be reviewed by the COI Committee, which is a committee comprised of faculty peers. The COI program staff will work with you to prepare for the COI Committee review by gathering any additional information needed about your SFI and related research. 

It is possible that the COI Committee will determine that your SFI needs to be managed. A Management Plan is a set of requirements outlined by the Individual COI Committee and agreed to by the Investigator. The Management Plan requirements 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. 

Committee Membership

The Individual COI Committee is comprised of faculty from a broad range of disciplines from across the different academic colleges at University Park and the Commonwealth Campuses. As required by policy RP06, at least one active human participants investigator serves on the committee at all times. Members are appointed by the Executive Vice President and Provost of Penn State.

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.


Individual COI Meeting Schedule

Disclosure Forms must be
submitted by 4:00 pm on:
Meeting Dates (called to order at 9:30 am)
January 10, 2024 January 19, 2024
February 7, 2024 February 16, 2024
March 6, 2024 March 15, 2024
April 10, 2024 April 19, 2024
May 8, 2024 May 17, 2024
June 12, 2024 June 21, 2024
July 10, 2024 July 19, 2024
August 7, 2024 August 16, 2024
September 11, 2024 September 20, 2024
October 9, 2024 October 18, 2024
November 6, 2024 November 15, 2024
December 11, 2024 December 20, 2024