Research Faculty Disclosure Guide
Faculty engaged in research may use this resource to help determine if an activity requires disclosure and / or prior approval per Penn State policies RP06 Disclosure and Management of Significant Financial Interests and AC80 Faculty Outside Professional Activities and Conflict of Commitment.
- This resource includes but is not limited to activities that require disclosure, prior approval, or further review under both AC80 and RP06.
- Faculty engaged in research are required to disclose certain significant financial interests if they met thresholds set forth in PR06 (noted below).
- Outside Professional Activities that must be disclosed under AC80 do not have time or compensation thresholds.
- Some outside professional activities require prior approval. Be sure to review and follow any college or department specific guidelines related to disclosure of outside professional activities and conflict of commitment.
- If you have questions about which activities require review and approval under either policy, please email coinsadmin@psu.edu.
COINS Resources
Looking for assistance with requesting prior approval and / or disclosing outside activities and interests in COINS?
- Use the COINS Quick Start Guide for streamlined submission instructions.
- For more detailed guidance and step-by-step instructions, please visit the COINS Learning Path webpage.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Starting/operating your own company |
Yes (be sure to request prior approval before filing the paperwork to start your company) |
Yes |
| Private consulting that does not involve research | No | Yes |
| Being an expert witness | No | Yes |
| Practicing a licensed profession (e.g., veterinarian, architect, nurse, attorney) | No | Yes |
| Chairing a master's or doctoral thesis committee at another university | Yes | Yes |
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Board of Directors: Serving on the board of a for-profit corporation (publicly traded or privately held), a non-profit organization, or a professional association. |
No |
Yes |
| Board of Trustees Membership: Serving on the board of a university, college, hospital, foundation, or other institution. | No | Yes |
| Executive Officer Roles: Holding positions such as CEO (Chief Executive Officer), CFO (Chief Financial Officer), COO (Chief Operating Officer), President, Vice President, etc., in any type of organization. | Yes | Yes |
| Fiduciary Roles: any role where you have a legal obligation to act in the best interests of another party | Yes | Yes |
Public and Non-Public Equity
There is no financial threshold for certain researchers. See IMPORTANT note below the table in this section.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
| Holding any equity in a private company | Yes (request approval before filing the paperwork to start the company) | Yes |
| Holding equity in a publicly traded entity | No |
Yes1 Exclusion: income from investment vehicles, such as mutual funds and retirement accounts, if the Investigator does not directly control the investment decisions made in these vehicles. |
| Receiving compensation from a publicly traded or non-publicly traded entity | No |
Yes1 |
1Disclose in COINS if financial interest is greater than $5,000 and in your area of expertise (or reasonably related to your Penn State Institutional Responsibilities). IMPORTANT: There is a zero-dollar threshold for compensation or equity if you are:
- A College of Medicine Investigator and the compensation or equity is related to human subjects research or purchasing authority; OR
- A Penn State Health employee affiliated with the College of Medicine and the compensation or equity is related to human subjects research or purchasing authority.
Sponsored or Reimbursed Travel
There is no financial threshold for certain researchers. See IMPORTANT note below the table in this section.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Sponsored or reimbursed travel (travel paid for an entity other than Penn State) |
No |
Yes1 Exclusion: Do not disclose travel that is reimbursed or sponsored by a federal, state, or local government agency in the United States, an American institution of higher education as defined at 20 U.S.C. 1001(a), an American academic teaching hospital, an American medical center, or a research institute that is affiliated with an American Institution of higher education. |
1Disclose in COINS if financial interest is greater than $5,000 and in your area of expertise (or reasonably related to your institutional responsibilities). IMPORTANT: There is a zero-dollar threshold for sponsored or reimbursed travel if you are:
- A College of Medicine Investigator and the travel interest is related to human subjects research or purchasing authority; OR
- A Penn State Health employee affiliated with the College of Medicine and the travel interest is related to human subjects research or purchasing authority; OR
- A Department of Energy (DOE) researcher and submitting a proposal to or supported by funding from the DOE.
Intellectual Property
There is no financial threshold for certain researchers. See IMPORTANT note below the table in this section.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
| An activity involving the conveyance of IP rights to another entity | Yes | Yes (disclose the related significant financial interest and/or outside professional activity) |
| Income from IP, including patents, licensing income, royalties, or copyright. This includes income received from the Penn State Research Foundation (PSRF). | No |
Yes1 |
1Disclose in COINS if financial interest is greater than $5,000 and in your area of expertise (or reasonably related to your Penn State Institutional Responsibilities). IMPORTANT: There is a zero-dollar threshold for IP if you are:
- A College of Medicine Investigator and the IP interest is related to human subjects research or purchasing authority; OR
- A Penn State Health employee affiliated with the College of Medicine and the IP interest is related to human subjects research or purchasing authority; OR
- A Department of Energy (DOE) researcher and submitting a proposal to or supported by funding from the DOE.
Appointments, Research or Teaching for an Outside University or Entity
There is no financial threshold for certain researchers. See IMPORTANT note below the table in this section.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Outside Teaching during the appointment period |
Yes |
Yes |
| Outside Teaching outside the appointment period | No |
Yes |
| Participating in programs sponsored by foreign governments | Yes | Yes |
| Conducting short courses including non-credit or professional courses | No |
Yes |
| Scholarly collaboration with an institution of higher education where there is no compensation, agreement, contract, or required time commitment1 | No | No |
| Scholarly collaboration with an institution of higher education where there is compensation, agreement, contract, or required time commitment | Yes | Yes |
| Holding a foreign or domestic position or professional appointment at another university, (paid or unpaid) |
Yes Exclusion: Appointments for the purpose of teaching outside of the Appointment Period do not require prior approval. |
Yes |
| Running or having fiduciary responsibility for a research endeavor at another university (running a lab, institute or program) | Yes | Yes |
| Receiving compensation from a publicly traded or non-publicly traded entity | No | Yes2 |
| Becoming an employee of a third-party entity (includes advisory board positions that have fiduciary responsibilities) | Yes | Yes |
1This is a scholarly activity as defined by policy AC80.
2Disclose in COINS if financial interest is greater than $5,000 and in your area of expertise (or reasonably related to your Penn State Institutional Responsibilities). IMPORTANT: There is a zero-dollar threshold for compensation or equity if you are:
- A College of Medicine Investigator and the compensation or equity is related to human subjects research or purchasing authority; OR
- A Penn State Health employee affiliated with the College of Medicine and the compensation or equity is related to human subjects research or purchasing authority.
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Peer Review of articles and grant proposals1 |
No | Yes2 |
| Academic Program Review at another institution 1 | No |
Yes2 Exclusion: Do not disclose income from seminars, lectures, or teaching engagements sponsored by a U.S. government agency or U.S. institution of higher education. |
| Preparing scholarly publications1 | No | Yes2 |
| Editorial Services for educational or professional organizations1 | No | Yes2 |
| Leadership positions in professional societies1 | No | Yes2 |
| Service with accreditation agencies1 | No | Yes2 |
| Serving on an advisory committee or evaluation panel for government funding agencies, nonprofit foundations, or educational organizations1 | No | Yes2 |
| Serving on (but not chairing) master's or doctoral thesis committee at another university1 | No | Yes2 |
| Chairing a master's or doctoral thesis committee at another university | Yes | Yes |
| Musical and other creative performances and exhibitions1 | No | Yes2 |
| Presenting or conducting a workshop at professional meetings or other similar gatherings1 | No |
Yes2 Exclusion: Do not disclose income from seminars, lectures, or teaching engagements sponsored by a U.S. government agency or U.S. institution of higher education. |
1This is a scholarly activity as defined by policy AC80.
2Disclose in COINS if financial interest is greater than $5,000 and in your area of expertise (or reasonably related to your institutional responsibilities).
| Activity | Request Prior Approval in COINS | Disclose in COINS |
|---|---|---|
|
Exceeding monthly or annual time limits |
Yes NOTE: Exceeding the annual time limits requires approval by the Provost |
Yes (disclose the related significant financial interest and/or outside professional activity) |
| Involving undergrad or graduate students in the outside activity | Yes | Yes (disclose the related significant financial interest and/or outside professional activity) |