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systems (PHS-FITS and FIDES), which will remain available in a read-only state, some of the documents below may be outdated.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

FCOI Disclosure in FIDES

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)

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.