PHS and NSF regulations and sponsor requirements guide Penn’s research-related conflicts of interest policy, originally effective August 24, 2012; effective as updated August 14, 2017, and November 21, 2022.
FCOIs may exist when financial considerations have the potential to compromise or bias professional judgment or objectivity regarding the design, conduct, or reporting of research. The University has one policy governing research-related FCOIs, the University of Pennsylvania Policy on Conflicts of Interest Related to Research (the FCOI Policy).
This policy is distinct from School-based annual extramural activity reporting policies and is designed to reduce, manage, and / or eliminate identified financial conflicts related to specific research projects. Prior to participating in research that will be funded by the Public Health Service (PHS) and the Patient-Centered Outcomes Research Institute (PCORI), the FCOI Policy requires Investigators to submit a Research, Interests, and Activities (RIA) disclosure form to their Schools. Depending on the nature and value of financial interests disclosed and whether those financial interests are determined by their School to be related to a PHS or PCORI proposal, disclosures may be routed to the Research Integrity Office for review. Additionally, disclosures related to all other research may require disclosure in the Financial Interest Disclosure Electronic System (FIDES).
In addition to meeting the above disclosure obligations, Investigators must receive FCOI training prior to engaging in research at the University and at least every four years.
IMPORTANT NOTE: As of 7/24/2023, the Research, Activities, and Interests (RIA) system has replaced the PHS Financial Interest and Travel Statement (PHS-FITS) and will also replace the Financial Interest Disclosure Electronic System (FIDES) later in 2023. For more information about the RIA system, including instructional documents, please click here.
As we continue to phase out legacy systems (PHS-FITS and FIDES), which will remain available in a read-only state, some of the documents below may be outdated.
For further information please see:
Overview of Policy on Conflicts of Interest Related to Research
Comparison of Different Financial Disclosure Requirements at Penn
Special Disclosure Process for PHS-funded Projects – How to submit a PHS Financial Interest and Travel Statement (PHS-FITS)
(please use RIA for PHS- and PCORI- funded projects)Investigator Decision Tree: The Who, What, Where and When for Disclosure Requirements at Penn
FCOI Core Program Disclosure Review and Management
FCOI Procedures for PHS Subawards from Penn to Other Institutions
Research-related Conflict of Interest (FCOI) Training
(now included in RIA)
For questions regarding FCOI, please Email coi@pobox.upenn.edu.
Research at Penn 2022 »
Volume 20
Research at Penn 2021 »
Volume 19
Research at Penn 2020 »
Volume 18
Research at Penn 2019 »
Volume 17
Research at Penn 2018 »
Volume 16
Research at Penn 2017 »
Volume 15
PCI Commercialization Guide »
Spring 2017
Research at Penn 2016 »
Volume 14
Research at Penn 2015 »
Volume 13