Individual Conflict of Interest

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. 

• FDA Regulation Title 21, Part 54 - Financial Conflicts of Interest
• NIH Regulation Title 42, Part 50.604 - Financial Conflict of Interest Regulation
• NIH Regulation Title 45, Part 94.4 - Financial Conflict of Interest Regulation
• NSF Grant Policy Manual - Conflict of Interest Policy

• Administrative Review and Processing of COI Disclosures
  

• Handling of Noncompliance
  

• Handling of Disclosures of SFI and COI Related to PHS-Sponsored Research

• Recommended Disclosure Language (pdf)

• 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)