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.

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. When required under Penn’s FCOI policy, disclosure of financial interests related to a specific research project should be submitted electronically through the Financial Interest Disclosure Electronic System (FIDES). FIDES disclosures are initially reviewed by the OVPR and may be referred to the Conflict of Interest Standing Committee (CISC) for further review and recommendations.

Prior to participating in research that will be funded by the Public Health Service (PHS), the FCOI Policy also requires Investigators to submit a Financial Interest and Travel Statement (PHS-FITS) 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 proposal, Investigators may be required to provide a more detailed disclosure in 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.

For further information please see: 

Overview of Policy on Conflicts of Interest Related to Research

Comparison of Different Financial Disclosure Requirements at Penn

FCOI Disclosure in FIDES

Special Disclosure Process for PHS-funded Projects – How to submit a PHS Financial Interest and Travel Statement (PHS-FITS)

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

NIH: Federal Regulations Governing FCOI (Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors, 42 CFR Part 50; Subpart F; 45 CFR Part 94)

FDA Regulation 21 CFR Part 54

For questions regarding FCOI, please Email  coi@pobox.upenn.edu.