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Financial Conflicts of Interest in Research Program


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.

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.

Further Information


U.S. Federal Policies