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Federal Requirement to Disclose Significant Financial Interest
Briefing Sheet The National Science Foundation (NSF) and the Public Health Service (PHS) require disclosure of significant financial interests by investigators receiving support for research and other sponsored activities from those sponsors either directly or via subaward. The American Cancer Society, American Heart Association, UC Discovery Grants, UCOP Special Research Programs, California Institute for Regenerative Medicine, and International Vaccine Institute have also adopted the federal requirements. What is filed: A Conflict of Interest Checklist is the initial certification statement signed by the Principal Investigator (PI)/Project Director (PD) on behalf of the whole research team. The named PI or PD on the project is required to certify via the Checklist that all responsible project personnel are knowledgeable about the policies and that all required Federal Financial Disclosure Forms are included with the proposal submission. Each individual who has a disclosable interest must complete the Federal Financial Disclosure Form, which has been created by UC Berkeley to meet the federal requirements. Who Files: All Principal Investigators, Project Directors, Co-Principal Investigators, and any other members of the research team (e.g., post-docs) who will be responsible for the design, conduct, or reporting of the proposed project. When are disclosures filed: At the time a new proposal is submitted to the sponsor and whenever there is a change in the financial interests of a responsible individual. The initial disclosure must accompany the proposal submitted to the Sponsored Projects Office. What is disclosed: All financial interests of the responsible individual, spouse, and dependent children exceeding $10,000 or 5% ownership in entities that might be affected by the research being conducted on the proposed project. Financial interest means anything of monetary value, including salary or other payments for services (from any sources other than UC), equity interests, and intellectual property rights (patents, copyrights, and royalties from such rights.) Review of disclosures: Department Chairs, Organized Research Unit (ORU) Directors, and Deans of single department Schools act as the first-level reviewing officials at UCB. The first-level reviewing official determines whether or not a conflict of interest may exist. Managing the potential conflict: The UCB faculty Conflict of Interest (COI) Committee reviews all positive financial disclosures and takes the necessary steps to manage, reduce, or eliminate any conflicts of interest before approval is granted. Approval of the financial disclsoure by the COI Committee is required before expenditure of any funds can be made from an award. The COI Committee is also responsible for making required notifications to the funding agencies regarding management, reduction, or elimination of any conflict. |
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