Important Information Regarding PHS COI Regulations

UC Berkeley CALmessages Notice

Date: August 20, 2012
Sender: Graham Fleming, Vice Chancellor for Research
To: All Academic Titles
Subject: Important Information Regarding PHS COI Regulations

Dear Colleagues,

I would like to highlight an important administrative hurdle contained in the new PHS COI regulations, which may affect the timely submission of proposals for a small number of UC Berkeley Principal Investigators. This could affect PIs submitting proposals with sub recipients who do not have their own PHS-compliant FCOI programs in place -- primarily those involving foreign entities.

Any sub recipients without PHS-compliant policies must agree to comply with UC Berkeley’s program. In addition, investigators (as defined by PHS) of those entities are subject to the same policies, procedures and processes -- and associated timelines -- as the UC Berkeley investigators.

The new PHS regulation requires that financial disclosures for all investigators must be submitted at the time of the application for PHS funding.

This new PHS requirement means that financial disclosures for UC investigators and any sub recipient investigators from entities without a PHS-compliant program must be included along with your proposal to the Sponsored Projects Office. Principal Investigators and the administrative staff assisting them must consider this requirement when submitting proposals in accordance with campus internal deadlines. A proposal that does not include the required financial disclosures for the UC investigators and any sub recipient investigators (from entities without PHS-compliant programs) cannot be submitted without violating the revised PHS regulations.

The campus implementation of the new policy, as well as new financial disclosure forms, instructions and guidance will soon be posted on the COI Committee website at

source: UC Berkeley CALmessages: