Completing your disclosures (investigators)

An interactive version of this guide is available using the button below.

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What RIA asks of investigators

All investigators submit a disclosure, even if they have no significant financial interests (SFIs). For each new project or protocol, investigators with SFIs or intellectual property (IP) interests also complete a Research Relatedness Assessment (RRA), which asks whether any of those interests are related to that research.

RIA pulls data from Penn Community, PennERA, eIRB and Inteum, so much of your information is already there.

RIA emails you from Penn Research (no-reply@apps.research.upenn.edu) when:

1. You're a new researcher who has never submitted in RIA, or your disclosure is about to expire.
2. You're identified on a new project or protocol.
3. You submit a new SFI or IP interest.
4. Penn Center for Innovation's IP database reports a new IP interest in your name, such as a new patent.

Click the link in the email (Submit Disclosure or Submit Research Relatedness Assessment), or log in directly at https://apps.research.upenn.edu/.

Complete FCOI training

Training is completed as part of your disclosure form. There's no separate task for it. It stays active for four years.

1. Log in and hover over the Research, Interests, and Activities (RIA) tab.
2. Select My Outside Activities & Interests.
3. Scroll down, or use the navigation menu on the left, to Initial Questions.
4. Answer YES to the first question. It may already be set to YES if you're on current research. Penn Investigator FCOI Training then appears in the Training to Complete section, above Initial Questions.
5. Click Review Course and read through the whole course.
6. At the end, check the attestation box below the course material.
7. Click Submit.

If the checkbox or buttons don't respond, maximize your browser window.

Complete a new disclosure

The disclosure (the Outside Activities and Interests form) covers Outside Activity, Equity and Ownership Interest, and Intellectual Property Interest. Depending on your school, it also covers Travel and Gifts.

1. Read the blue-box instructions at the top of the form. They set the guidelines for reporting outside interests.
2. Answer the Initial Questions. They include University-wide and school-specific questions. Hover over the info icon next to a question for more context, and over any blue text for its definition.
3. Outside Activities: if you select YES, add each outside organization you're involved with. If an organization isn't in the database, select CAN'T FIND - ADD NEW. The form asks about your role, time, University involvement and compensation. Click Save, or Save and Add Another for more activities with the same organization.
4. Repeat for Equity and Ownership, Intellectual Property, and Travel and Gifts if they appear.
5. Check the Attestation box.
6. Click the button shown at the bottom: Save and Continue, Submit for Review, or Save and Complete, depending on your disclosure.

To stop and finish later, click Save Draft. A draft isn't routed for review.

RIA keeps everything you enter. Review and update it at least once every 12 months, and within 30 days of acquiring any new SFI.

Complete a Research Relatedness Assessment (RRA)

You'll get an email and a task in RIA each time you're identified on a new project or protocol.

1. Click Submit Research Relatedness Assessment in the email, or log in and click the task titled Research Relatedness Assessment Required - Project ID. All your tasks are under Profile & Settings -> My Tasks.
2. Read the instructions on reviewing your outside interests.
3. Scroll down to the summary of the outside interests you submitted before. Select Update if anything is out of date, otherwise select Confirm.
4. If you have SFIs, the RRA form opens. Mark which outside organizations are related to this research and which aren't. If you're unsure, select Help Me Decide, complete the Relatedness Questionnaire, and click Save. The system determines relatedness from your answers.
5. If any organization is related, a Project Questions panel appears. Complete it.
6. Check the Attestation box and select Submit for Review.

If you have no SFIs or IP interests, there are no questions to answer. Open the task, confirm your interests, and it's complete.

Modify your annual disclosure

1. Select Research, Interests, and Activities (RIA), then My Outside Activities & Interests.
2. Select Modify. A warning says this reopens your disclosure for editing. Click OK.
3. Add or edit interests. For example, to add an outside activity, change the answer from NO to YES, select Add Outside Activity, and complete the pop-up. Click Save, or Save and Add Another for more activities with the same organization.
4. Check the Attestation box and select Save and Complete. Your changes aren't routed for approval until you do.

Modify a submitted RRA

You can change a NO answer to YES yourself. You can't change a YES to NO in the system. For that, contact the Research Integrity Office at coi@pobox.upenn.edu.

1. Click the RIA tab, then Search Research Relatedness Assessments.
2. Choose the project from the list, or search by ORS or IRB number.
3. Click the Edit icon next to the project.
4. Select Modify in the blue box at the top of the screen. A message warns that this creates a new draft. Click OK.
5. Change your answers. When you change NO to YES, Project Questions appear for you to answer.
6. Check the Attestation box and select Submit for Review.

Review and approve intellectual property interests

All Penn IP is loaded into RIA automatically.

1. Go to your Tasks page and click IP record(s) identified - Disclosure Request.
2. Scroll to the Intellectual Property Interest section. Your Penn IP appears in a table.
3. Select Answer Questions for each record, review the questions and click Save. Your answers save automatically, and completed reviews move to the table below.
4. Also disclose any IP not assigned to Penn that you've received payments for. Use Add Intellectual Property Interest and complete the pop-up.

If your Penn IP records look wrong, email support@research.upenn.edu. Answer IP tasks promptly: an IP task left open for 30 days or more removes your FCOI clearance on every project.

Terms

• SFI (significant financial interest): an activity, equity or IP interest that is worth more than $5,000, is equity in a private company, or is a fiduciary role.
• IP (intellectual property interest): your financial, legal or ownership rights in patents, copyrights or other innovations.
• RRA (Research Relatedness Assessment): the project-specific disclosure that connects you to a project or protocol.
• FCOI (financial conflict of interest): a related SFI that could directly and significantly affect the design, conduct or reporting of the research.