Service Related

Conflict of Interest
Policy Scorecard

Pennsylvania State University College of Medicine

Service Related COI Grade:

Fee-For-Service Policy:

Self-Referral Policy:

Policy absent or unlikely to have substantial impact

Model policy

Policy Excerpt:

"A conflict of interest may take various forms but exists if a significant financial interest or other opportunities for tangible personal benefit may exert a substantial and improper influence upon an employee. A conflict of interest may exist when there is a divergence between the private interests of an employee and the employee’s obligation to the Corporation such that: (i) a reasonable and independent observer might rationally question whether the employee’s professional responsibility might be influenced by considerations of gain or financial interest for either the employee or the employee’s family or for other parties; or (ii) a reasonable and independent observer might rationally conclude that the conflict of interest undermines the integrity of any business of the Corporation."

"Significant Financial Interest (SFI). An employee has a significant financial interest if the employee has, directly or indirectly, through business, investment or spouse/partner/dependent child(ren), one or more of the following interests that reasonably appear to be related to the employee’s Institutional Responsibilities:
(a) An existing or potential ownership or investment interest, in any entity with which the Corporation has a transaction, contract or other arrangement, or
(b) A compensation arrangement with any entity or individual that the Corporation has a transaction, contract or other arrangement, or
(c) An existing or potential ownership or investment interest in, or compensation agreement with, any entity or individual with which the Corporation is negotiating a transaction, contract, or other arrangement, or
(d) An existing or potential ownership or investment interest in, or compensation arrangement with, any entity whose business or operation has been or will be directly affected by a decision or action of the Corporation, and
(e) For publicly traded entities, if the value of any remuneration received from the entity over a period of twelve months combined with the value of any ownership or equity interest exceeds $5,000.
(f) For non-publicly traded entities (including but not limited to private “start-up” companies, closely held corporations, partnerships, or sole proprietorships), if either the value of any remuneration, when aggregated, exceeds $5,000 over a period of twelve months; or, the investigator holds any equity interest.
(g) Intellectual property rights and interests (e.g., patents, copyrights) upon receipt of income related to such rights and interests (including but not limited to royalties, or licensing revenues) that exceeds $5,000 over a period of twelve months.
(h) All reimbursed or sponsored travel exceeding $5,000 from an entity over a period of twelve months; however, 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 does not need to be disclosed as an SFI.
(i) Any financial interest in a for-profit entity or any intellectual property, regardless of income generated, if related to human subjects research conducted at Penn State"

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