Individual Conflict of Interest

Penn State’s Individual Conflict of Interest (COI) Committee and program exist to maintain the integrity of Penn State research, learning, service by reducing or eliminating real or perceived financial conflicts of interest investigators may have.

The Individual COI Committee and program operates under Individual Conflict of Interest Policy.

If you have questions about individual COI and COI disclosure, please email or call 865-1775.

An Individual COI Committee meets at University Park and another at the College of Medicine. Investigators whose primary affliation is with the College of Medicine should go to the COM Conflict of Interest website.


We help investigators mitigate potential bias and the perception of bias when they have significant financial interest (SFI) in their University duties. For this, all Penn State investigators must disclose any SFI they have have related to their institutional responsibilities. The disclosure is reviewed either administratively or by the Individual (COI) Committee, who develop conflict of interest Management Plans when necessary.

All faculty must disclose SFI, but staff, students, administrators and other officials may be investigators who are also required to disclose. An "investigator"is any individual who has the ability to make independent decisions related to the design, conduct, or reporting of University Research.

"Institutional Responsibilities" are an Investigator's professional responsibilities on behalf of the University. Examples include, but are not limited to:

  1. research (regardless of whether or not it is funded);
  2. research consultation;
  3. teaching;
  4. outreach;
  5. professional practice (e.g., clinical medical practice, veterinarian practice, practice of law);
  6. University committee memberships (e.g., Faculty Senate, Purchasing Committees); and
  7. service on University panels, such as an Institutional Review Board ("IRB") or Data or Safety Monitoring Boards.

If a investigator has a financial interest related to their institutional responsibilities, he or she must disclose that interest if it meets any of the following thresholds for SFI below: 

  • Compensation/Remuneration received from an entity other than the University exceeding $5,000 in the previous 12-month period.;
  • Any equity interest (e.g., stock, ownership rights) in a non-publicly traded entity regardless of amount (i.e., there is no de minimis);
  • Equity interest (e.g., stock, ownership rights) in a publicly-traded entity exceeding $5,000 (or, if the value of any equity interest plus any compensation from the same entity exceeds $5,000);
  • Intellectual property rights (e.g., patents, copyrights) upon receipt of income related to such rights and interests  that exceeds $5,000 in the previous 12 month period; or
  • Reimbursed or sponsored travel paid by an entity other than the University that exceeds $5,000 in the previous 12 month period. (Travel that is reimbursed or sponsored by a federal, state, or local government agency in the United States, an American Institution of Higher Education as defined at 20 U.S.C. 1001(a) , an American academic teaching hospital, an American Medical Center, or a research institute that is affiliated with an American Institution of higher education does not need to be disclosed as an SFI).

With some exceptions, investigators should not disclose any financial interests that are not related to their institutional responsibilities.

All SFI disclosures must be made using COINS, Penn State’s web-based Conflict Of INterest System. Investigators are required to disclose all SFI 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.

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.

All 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.

All disclosures are confidential and will only be shared to the extent necessary to manage any identified conflicts of interest.

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. 

Additional Resources

In addition to Penn State's Individual Conflict of Interest Policy, the following resources can help you understand financial conflict of interest and its managment.

About the Individual COI Committee

The Individual COI Committee is appointed by the Provost. The Director of the Office for Research Protections serves as the Conflict of Interest Official for the University.

The Committee is comprised of:

  • Faculty representation from a minimum of two (2) of the following disciplines:

    • Agricultural Sciences
    • Earth and Mineral Sciences
    • Engineering
    • Health and Human Development
    • Science
  • One (1) faculty representation from the social sciences/humanities
  • One (1) active human participants investigator

2020 Individual Conflict of Interest Meeting Schedule at University Park

Meetings are called to order at 9:30 a.m.

Disclosure Forms must be
submitted by 4:00 pm on:
Meeting Dates
January 8, 2020 January 17, 2020
February 12, 2020 February 21, 2020
March 11, 2020 March 20, 2020
April 8, 2020 April 17, 2020
May 6, 2020 May 15, 2020
June 10, 2020 June 19, 2020
July 8, 2020 July 17, 2020
Augut 12, 2020 August 21, 2020
September 9, 2020 September 18, 2020
October 7, 2020 October 16, 2020
November 11, 2020 November 20, 2020
December 9, 2020 December 18, 2020

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.