Disclosure FAQs

Conflict of Interest Contact

101 Technology Center, University Park, PA 16802
Phone: 814-865-1775 • Fax: 814-863-8699
Email: coinsadmin@psu.edu

The Conflict of Interest Program in the Office for Research Protections manages all Significant Financial or Business Interest Disclosures for Penn State faculty, staff, and students.

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Conflict of Commitment Frequently Asked Questions

A Conflict of Commitment can arise when you participate in Outside Professional Activities (paid or unpaid) that may interfere with your primary responsibilities to the University. To read more about Conflicts of Commitment and Outside Professional Activities, including who needs to disclose and when, please visit the ORP's Conflict of Commitment webpage.

Conflict of Commitment FAQs

: All outside professional activities related to the your area of expertise require disclosure, even if the activity was previously approved.
: The outside professional activities listed in Policy AC80 require prior approval.
: Yes, all outside professional activities, including teaching outside of the appointment period require disclosure. However, outside teaching outside of the appointment period does not count towards the monthly or annual time limits.
: 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.
: 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.
: No, prior approval is only required if chairing at another university (either foreign or domestic).
: Generally speaking, disclosures in COINS are related your significant financial interests, such as holding equity in a publicly traded entity, income from intellectual property, and sponsored travel (thresholds apply and can vary by sponsor) and usually do not require prior approval of disclosure under AC80. However, there are certain activities that do need disclosed / approved per AC80 and disclosed in COINS per RP06. Review the Faculty Disclosure Guide for more information, guidance, and examples.
: Running a company does not require ongoing approval under AC80. However, company ownership requires disclosure in COINS per RP06. In addition, you must disclose the time spent on company activities per AC80. Also, 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 for those specific activities.
: 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.
: 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.
: Send the contract to obaAdmin@psu.edu. Program staff can review the contract to see if it conflicts with any University policies and provide guidance on next steps.
: 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.
: Yes, any 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 request prior approval in advance.
: 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.).
: 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.
: Per policy FN14, “the use of email, internet, and office phone services for reasonable personal use is permitted if the University incurs no additional incremental cost for personal use. These services may never be used in the conduct of a personal business or any other for-profit venture from which the employee (or member of their family) would receive personal gain.” Using University facilities is only allowed if the facility is open to the public, and if the proper agreements have been executed. If your company wants to sponsor research at Penn State, contact the Office for Sponsored Programs.
: Small consulting projects are typically permissible. Larger projects are handled on a case-by-case basis and is dependent on the amount of time you are spending and the amount. However, if the consulting work involves conducting research, this will require prior approval.
: 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 Frequently Asked Questions

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. To read more about Conflicts of Interest, including who needs to disclose and when, please visit the ORP's Conflict of Interest webpage.

Conflict of Interest FAQs

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 Faculty Outside Activities and Disclosure Guide for additional information.

No. Grants through OSP are supporting your institutional responsibilities at the University.

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.

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.

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.

Yes, if related to your institutional responsibilities at the University, for example, a company which will commercialize an invention you created at Penn State.

You must disclose within 30 days of acquiring a new SFI. Therefore, you will need to disclose within 30 days of filing the paperwork to start your company. However, you are welcome to disclose in COINS prior to this, if desired. When adding the entity in COINS, make a note in the description field indicating when you plan to form the company. NOTE: You must secure pre-approval per policy AC80 prior to filing the paperwork to start your company.

Yes, if your company is not yet dissolved, you need to disclose it.

Yes, you must disclose your company ownership in COINS and then disclose the time spent on your company’s activities via the AC80 disclosure form.

No. Ownership in pooled investment vehicles, such as mutual funds and retirement accounts, is not considered SFI as long as you do not directly control the investment decisions made in these vehicles.

You only need to disclose stocks which you control directly, the value is above the threshold, and related to your institutional responsibilities. Mutual funds do not allow individual investors to make decisions about which specific stocks to buy or sell.

You do not need to disclose each time the stock goes above the threshold throughout the year. Just be sure to update your annual disclosure if the stock is above the threshold at that time.

If you currently have SFI 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.

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 under AC80 or RP06.

Only disclose travel that is sponsored or reimbursed directly to you by an entity other than the University. Do not disclose in COINS if the University is paying for your travel, including travel paid from a grant or contract through Penn State. In addition, do not disclose in COINS if the travel is paid for 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 paid to you by the University.
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. However, your time spent on these activities may need to be disclosed under policy AC80.
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 under policy AC80.
Equity Interests in or income from “passive investments” such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions for these investment vehicles.
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.