Home » Office for Research Protections » Conflict of Interest » Disclosure FAQs
COI Menu
ORP Menu
- Office for Research Protections (ORP) Home Page
- Conflict of Interest
- Controlled Substances
- Drone Operations
- Dual Use Research of Concern (IRE)
- Education
- Export Control
- Human Stem Cells (ESCRO)
- Human Subjects Research (IRB)
- Radioisotopes (UIC)
- Institutional Biosafety Committee (IBC)
- Research Data Management Policy
- Research Integrity
- Research Security
- Scientific Diving
- Vertebrate Animal Care and Use (IACUC)
- Quality Assurance
- ORP Team
- ORP Events
- ORP Announcements
- Office for Research Protections (ORP) Home Page
- Conflict of Interest
- Controlled Substances
- Drone Operations
- Dual Use Research of Concern (IRE)
- Education
- Export Control
- Human Stem Cells (ESCRO)
- Human Subjects Research (IRB)
- Radioisotopes (UIC)
- Institutional Biosafety Committee (IBC)
- Research Data Management Policy
- Research Integrity
- Research Security
- Scientific Diving
- Vertebrate Animal Care and Use (IACUC)
- Quality Assurance
- ORP Team
- ORP Events
- ORP Announcements
Disclosure FAQs
Conflict of Commitment FAQs
Q: Which outside professional activities require disclosure?
A: All outside professional activities related to your area of expertise require disclosure, even if the activity was previously approved.
Q: Which outside professional activities require prior approval?
A: The activities listed in Policy AC80 require prior approval.
Q: Does all outside teaching require disclosure, even outside of the appointment period such as in the summer?
A: Yes, all outside professional activities outside of the appointment period require disclosure. However, outside professional activities outside of the appointment period do not count towards the monthly or annual time limits.
Q: What foreign activities require prior approval? Which foreign activities require disclosure?
A: Participating in a foreign talent recruitment program is one specific type of activity that requires both prior approval and disclosure. Generally, foreign activities are treated the same as domestic regarding prior approval and disclosure. It is the type of activity that determines if something needs prior approval or disclosure.
Q: In what cases are foreign activities treated differently than domestic activities?
A: Under policy AC80, foreign activities are not treated differently than domestic activities. For example, teaching at either a foreign university or domestic university requires both prior approval and disclosure if during the appointment period. (If outside the appointment period, it only requires disclosure.) Under policy RP06, foreign teaching needs to be disclosed in COINS if thresholds apply while domestic teaching does not.
Q: If a faculty member receives prior approval to start a company, do they need to request prior approval from their department head to continue to run the company in subsequent years?
A: Running a company does not require ongoing yearly approval. However, if you later decide you want to involve students, or if you are going to exceed the time limits, then you will need to request prior approval in COINS for those specific activities.
Q: How do I disclose company ownership in COINS?
A: Within 30 days of starting your own company, disclose company ownership in COINS by selecting the disclosure type “Non-Public Equity.” Then, disclose the time that you spent on company activities in the previous 12 months under the disclosure type “Consulting, Professional Services, Outside Employment or Operating Own Company.”
Q: Can faculty teach a course that is similar to the one they teach for Penn State at another university during the summer (when they are off contract)?
A: Per policy AC80, all outside professional activities (on or off contract) should not compete with coursework or services provided by the University. The University understands that this is your area of expertise and may be similar, so speak to your department head if this competes with University coursework.
Q: Can faculty help design curricular programs that mirror the University’s programs at other institutions?
A: Per policy AC80, all outside professional activities should not compete with coursework or services provided by the University. Consult with your department head to determine if it competes with the University’s curriculum.
Q: Can University employees negotiate a contract from a company for which they have partial ownership?
A: No, University employees (faculty and staff) cannot negotiate a contract on behalf of Penn State with their company, nor can they negotiate a contract on behalf of their company with Penn State. If you want to use your company as a supplier, you must go through Purchasing.
Q: If a faculty member receives prior approval to teach a course for another institution, and is later (e.g., the following year) invited to teach a different course, do they need to request prior approval from the department head again?
A: Yes, if teaching different course, this is a new activity. New activities require prior approval. However, if you know you are going to be teaching the same course for more than one semester, you can indicate this in your prior approval request in COINS.
Q: When an outside activity exceeds Policy AC80’s limit on hours, how often should the faculty member request approval for the activity – just once or annually?
A: When requesting approval for exceeding the time limits, you can indicate how often you plan on exceeding it during that year (just once, every month, etc.).
Q: What types of appointments or titles can faculty hold at other universities? Can faculty hold tenure at another university?
A: Full-time faculty cannot hold tenure at another university. Holding any appointment or professional position another university requires prior-approval and then disclosure under policy AC80. The only exception is if the appointment is solely for teaching outside of the appointment period, for example, teaching a course in the summer.
Q: How would a faculty member appeal a denial of prior approval?
A: Any faculty member can submit an appeal to the University Faculty Senate Faculty Rights and Responsibility Committee. The process and form are located on the University Faculty Senate website.
Conflict of Interest FAQs
A conflict of interest in research can occur when you are in a position of influence on a research project, and your financial interests outside of the University are such that you or your family members could potentially benefit from the outcome of the research.
Q: What financial interests do I have to disclose?
A: Penn State policy RP06 requires investigators to disclose significant financial interests received by the investigator and / or their spouse/partner or dependent children if the financial interests are related to their institutional responsibilities. Examples include (but are not limited to) holding equity in a publicly traded company, income from intellectual property, and sponsored travel (thresholds apply and can vary by sponsor). Review the Research Faculty Disclosure Guide for additional information.
Q: Should I disclose salary support I am receiving from a grant, if the grant is through the Office of Sponsored Programs (OSP)?
A: No. Grants through OSP are supporting your institutional responsibilities at the University.
Q: Do I need to disclose my compensation from serving as an expert witness?
A: If thresholds apply, this needs to be disclosed in COINS as a significant financial interest under policy RP06. In addition, being an expert witness is an outside professional activity that also needs disclosed under Policy AC80.
Q: Do I need to disclose compensation from speaking engagements at another university?
A: You only need to disclose in COINS if the university is a foreign university and thresholds apply. Compensation from lectures, seminars, or teaching from a US-based institution of higher education is excluded from disclosure, regardless of the amount received.
Q: Do I need to disclose compensation received from giving a presentation at a conference or other professional gathering?
A: If thresholds apply, you must disclose compensation received from presenting at a seminar (foreign or domestic location). If under the threshold, then this is a scholarly activity as defined by policy AC80 and it does not need to be disclosed.
Q: Do I need to disclose a gift used for research from a company in which I have a financial interest?
A: If you currently have financial interest in a company and the same company gives you a gift to be used for research, then the gift must be disclosed in COINS as a related research project. Even if you are not sure whether you will use the gift for work related to the company, please disclose it so that a review can be conducted. The University has specific policies and procedures regarding charitable contributions and what can be categorized as a gift. See policy RA04 and the Office for Sponsored Program’s website on Gifts and Charitable Contributions for more information.
Q: Do I need to disclose my scholarly collaboration with someone from a foreign university?
A: Unless there is a specified time commitment, a contract or agreement, compensation, or support for research (financial or in-kind, e.g., lab space, equipment) scholarly collaboration such as co-authoring a paper does not need to be disclosed.
Q: What financial interests are excluded from disclosure requirements?
A: Any of the following:
- Income paid to you by the University.
- Travel paid for or reimbursed directly to you by the University.
- Travel paid for by or reimbursed by a U.S. institution of higher education, U.S. teaching hospital, U.S. medical center, research institute associated with a U.S. institution of higher education, or U.S. federal, state, or local government agency.
- Income from seminars, lectures, or teaching engagements sponsored by a U.S. institution of higher education, U.S. teaching hospital, U.S. medical center, research institute associated with a U.S. institution of higher education, or U.S. federal, state, or local government agency. NOTE: your time spent on these activities may need to be disclosed in COINS.
- Income from service on advisory committees or review panels from a U.S. institution of higher education, U.S. teaching hospital, U.S. medical center, research institute associated with a U.S. institution of higher education, or U.S. federal, state, or local government agency. NOTE: Your time spent on these activities does not need to be disclosed in COINS.
Office for Research Protections
Address
200 Innovation Blvd.
Suite 110
University Park, PA 16802
The Office for Research Protections (ORP) ensures that research at the University is conducted in accordance with federal, state, and local regulations and guidelines that protect human participants, animals, students, and personnel involved with research.