Financial Interest Disclosure Electronic System (FIDES)	Print Issue
February 7, 2012, Volume 58, No. 21

The Office of the Vice Provost for Research (OVPR) in partnership with the Division of Information Systems and Computing is pleased to announce implementation of a new application to facilitate the disclosure of financial interests and relationships related to participation in specific research projects. The new system, FIDES, replaces the previous paper-based disclosure process. As of Wednesday, February 1, 2012, Investigators with a PennKey and Password may submit eDisclosures at any time via FIDES at  https://fides.isc-seo.upenn.edu using a Penn-supported web browser. 

How are Research-Related Conflicts of Interest (RCOI) Addressed at Penn?

The OVPR is directly responsible for the University’s RCOI Program. The financial disclosure requirement for Investigators participating in research arises in connection with each individual research project that is conducted by Penn faculty and staff, or that uses Penn resources. In contrast to annual extramural activities reporting required by the Schools, RCOI disclosure is triggered by specific events including submissions of proposals or protocols.

Why is Disclosure Required?

Financial or other personal considerations have the potential to compromise or bias professional judgment or objectivity of researchers. While bias need not be actually present, the appearance of bias in judgment is reason for concern.  Because RCOIs are inherent to the research enterprise, the governing federal regulations and University and School policies require disclosure of relevant financial interests and relationships.

Who Must Disclose?

Disclosure is required by each Investigator (any individual responsible for the design, conduct, or reporting of a research project) who at any time during the past 12 months through the next 12 months,  has or expects to have financial interests/relationships that may affect or be affected by the research. These include both financial interests of the Investigator, as well as those of a spouse, parent, child or entity controlled or directed by the Investigator or his/her spouse. To be reported also are any relationships of the Investigator or family members in or with any entity other than Penn whose interests may affect or be affected by the research.

When to Disclose

If required under Penn’s RCOI policies, Investigators should disclose in FIDES when:

• A research proposal is submitted to the  Office of Research Services; or
• A human subjects research protocol is submitted to the IRB; or
  
• A transaction is initiated by the Center for Technology Transfer involving technology in which the Investigator has a financial interest; or 
  
• There is a change regarding previously disclosed financial interests or relationships; or the Investigator has new financial interests or relationships relevant to ongoing research.

Benefits of FIDES

• Streamlined disclosure process allowing Investigators to clearly communicate detailed, up-to-date information about personal financial interests and participation related to specific research projects
• Improved efficiency of the disclosure review process by the Conflict of Interest Standing Committee
• Creation of a central disclosure repository, the Investigator Dashboard, where Investigators may view all past disclosures and disclosures in draft, as well as the review and management status of submitted disclosures
• Ability to identify a specific research protocol and/or proposal that is the subject of the disclosure
• Definitions tab and Infodots to provide additional guidance and examples for specific question
• Immediate email notification to the Investigator that a disclosure has been received by the OVPR
  
• Ability to upload supporting documentation and to submit an Addendum to amend previous disclosures

FIDES Help

Individual training in FIDES is available. The OVPR staff will be happy to provide individual guidance to any individual required to submit an electronic disclosure in FIDES. Individuals who wish to receive this individual instruction should contact the OVPR at (215) 898-3603 or via email at coi@exchange.upenn.edu

Questions

For additional information, please visit the OVPR website at www.upenn.edu/research/ or contact the OVPR at (215) 898-3603 or email at coi@exchange.upenn.edu

—Steven J. Fluharty, Senior Vice Provost for Research

—Robin H. Beck, Vice President, Information Systems and Computing