A step-by-step Reference Guide can be found here:
RIA FAQs
Investigators
Click on the Modify Disclosure button at the top of the page to add, edit or remove an Outside Activity, Financial Interest or IP interest.
Financial Conflict of Interest (FCOI) training is required every four years or whenever there are material changes to relevant regulations or University policies regarding conflicts of interest.
Institutional Responsibilities means are Investigator’s professional or employment-related responsibilities on behalf of the University or any of its Schools, which may include Research, Research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
Participating in research at Penn means being named as an investigator, listed as personnel, or otherwise being responsible for the design, conduct, or reporting of research related to any of the following
- A research proposal submitted for funding or an awarded grant or contract identified in PennERA
- An Institutional Review Board (IRB) protocol
- An Institutional Animal Care and Use Committee (IACUC) protocol
Other research agreement in the Research Inventory System (e.g. a Material Transfer Agreement)
Please confirm with the PI or BA that you are appropriately listed in PennERA and/or HSERA.
A Fiduciary Role is membership on the governing board of an Outside Organization, including service on its board of directors, or having a position of authority or responsibility to act in the best interest of the Outside Organization. This includes being an officer, manager, partner or limited liability company member with management responsibility.
A Financial Conflict of Interest (FCOI) is a Significant Financial Interest (SFI) that could directly and significantly affect the design, conduct, or reporting of the Research.
A Gift is an unconditional donation to an employee of the University for which the donor does not expect to receive any reciprocal benefit. Gifts are considered anything of significant value (i.e. greater than $100, consistent with IRS policy).
A Management Plan is a written plan that specifies actions that have been or will be taken to manage an Investigator’s Financial Conflict of Interest (FCOI) to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.
Public Health Service (PHS) agencies include:
- National Institute for Health (NIH)
- Federal Drug Administration (FDA)
- Health Resources and Services Administration
- Center for Disease Control (CDC)
- Agency for Healthcare Research and Quality
- Agency for Toxic Substances and Disease Registry
- Indian Health Service
- Substance Abuse and Mental Health Services Administration
- Administration on Aging
- Agency for Children and Families
- Office of Global Affairs
- Office of the Assistant Secretary for Preparedness and Response
A Research Project is any proposal identified in PennERA or an IRB protocol identified in HS-ERA.
A Research Relatedness Assessment is a self-assessment used to determine whether disclosed SFIs or IP interests could be affected by a research project or are with an entity whose financial interests could be affected by that research.
Significant financial interest (SFI) means one or more of the following of the Investigator (or the Investigator’s Family member) that reasonably appear to be related to the Investigator’s Institutional responsibilities:
i. With regard to any publicly traded Outside organization, an SFI exists if the value of any remuneration received from the Outside organization in the 12 months preceding the disclosure plus the value of any equity interest in the Outside organization as of the date of disclosure, when aggregated, exceeds $5,000. Remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;
ii. With regard to any non-publicly traded Outside organization, an SFI exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated, exceeds $5,000, or if the Investigator or Family member holds any equity interest (e.g., stock, stock option, or other ownership interest);
iii. Intellectual property rights and interests (e.g., patents, copyrights) not assigned to the University, upon receipt of any income related to such rights and interests;
iv. Clinical trial intellectual property rights (and royalties or other remuneration, if any, paid with respect to such rights); or
v. Any Fiduciary role in an Outside organization
An Equity Interest includes ownership interests or securities, including but not limited to shares of stock or securities, stock options, warrants or any other rights to purchase stock or securities, debt instruments, partnership interests in a general or limited partnership, or membership interests in a limited liability company. All equity and ownership interests should be disclosed regardless of whether they have any value, or their value cannot be determined.
An Excluded Payor is a Federal, state, or local government agency, a United States institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. Note that foreign government agencies are not Excluded Payors. By way of example, the University, the University of Pennsylvania Health System, Children’s Hospital of Philadelphia, the Philadelphia Veterans Affairs Medical Center, the Howard Hughes Medical Institute, and Wistar Institute are Excluded Payors.
An Intellectual Property or other financial interest is something you and/or a Family Member created, including but not limited to patent(s), patent application(s), copyrights, trademarks, or the right to receive compensation in connection with the development or sale of this creation.
An Outside Organization is any company, entity, or organization – other than UPenn / UPHS (and their corporately-owned entities), other US institutions of higher education (or affiliated teaching hospitals), US medical centers, US research institutes, or US government agencies.
Investigators must complete Financial Conflict of Interest (FCOI) training prior to engaging in research at the University and at least every four years. FCOI training is built into RIA and Investigators will be notified as the training date approaches.
My Payments is a tool designed to help you track incoming payments from Outside Organizations. This can be used for annual extramural reporting and/or SFI threshold monitoring purposes.
Prior Approval is the process of contract submission, departmental and/or school review, and approval prior to commencing activity with an Outside Organization.
RIA stands for Research, Interests, and Activities. It is the name of the system used to collect information about personal interests and activities that may have the potential to create real or perceived conflicts of interest.
The Conflict of Interest Standing Committee (CISC) is a faculty-based committee that serves in an advisory capacity to the Senior Vice Provost for Research, providing recommendations as to whether a Significant Financial Interest (SFI) constitutes a Financial Conflict of Interest (FCOI), whether the FCOI is manageable and, if so, how to structure the management plan.
The Office of Research Services (ORS) is responsible for supporting the University’s investigators and administrators by managing externally sponsored research projects through the pre-award and post-award processes. ORS administers sponsored projects and maintains electronic records via PennERA.
The Office of the Vice Provost for Research (OVPR) is an advisor to the Provost and has the oversight of the University’s vast research enterprise, encompassing a broad spectrum of research support services, regulatory bodies, multi-disciplinary campus-wide Centers and Institutes, and partnerships to further develop investigator intentions.
The Research Integrity Office (RIO) within the Office of the Vice Provost for Research is directly responsible for the University’s Research-Related Financial Conflicts of Interest (FCOI) Program.
The University’s policy on Conflicts of Interest Related to Research can be found in the Faculty Handbook.
The University’s policy on Conflict of Interest can be found in the Faculty Handbook, Section II.E.10.
A Family Member is a spouse or dependent child.
An Investigator is a project director, principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research, which may include collaborators or consultants and is identified as an Investigator in Penn’s systems. An individual may be identified as an Investigator on more than one Research Project.
Please create a ticket using the Help feature in the tool.
For questions regarding Financial Conflicts of Interest (FCOI), please email coi@pobox.upenn.edu