UC Berkeley Policy: Disclosure of Financial Interests Related to National Science Foundation (NSF) Sponsored Projects
Please note the following changes to the 1995 UC Berkeley policy:
- As of August 24, 2012, the Public Health Service (PHS) FCOI policy is separate and distinct from that of the National Science Foundation (NSF). This policy now applies to NSF only.
- NSF and Other Non-PHS Federal Financial Disclosure procedures are followed by each member of the research team who meets the federal definition of investigator, when the proposal is submitted to the Sponsored Projects Office.
- If the financial interests may reasonably be expected to have a direct and significant effect on the design, conduct, or reporting of the project, the disclosure will be referred to the standing Conflict of Interest Committee.
- Berkeley campus procedures have been reviewed by the Committee on Research and the Conflict of Interest Committee. If you have questions about implementation here at Berkeley, please contact Alaisha Hellman, Coordinator for the Conflict of Interest Committee Coordinator, 510/642-0122, firstname.lastname@example.org or email@example.com.
Date: September 8, 1995
Sender: Joseph Cerny, Vice Chancellor for Research
To: Deans, Directors, and Department Chairs
Subject: Disclosure for Federally Sponsored Projects
Subject: Disclosure of Financial Interests Related to Federally Sponsored Projects
On July 11, 1995, the National Science Foundation (NSF) and the Public Health Service (PHS) published final rules in the Federal Register requiring grantee institutions to establish procedures for disclosing project-related financial interests. The rules take effect October 1, 1995, for proposals submitted to NSF and PHS and will ultimately apply to all federal sponsors.
The regulations establish standards and procedures for institutions applying for NSF or PHS grants, contracts, subcontracts, or cooperative agreements. Principal investigators, co-principal investigators, and other individuals (e.g., postdocs) who have responsibility for the design, conduct, or reporting of a project must disclose their financial interests in any project-related entity before proposal submission. Recipient institutions will review and report existing and potential financial interests and assure that conflicts will be satisfactorily managed, reduced, or eliminated before expenditure of funds can be approved.
Principal investigators will certify on an addendum to Berkeley’s internal Sponsored Project Approval Form (SPAF) whether or not responsible personnel have disclosable financial interests. Disclosable interests will be reviewed by the dean, chair, or director of the administering unit (the “reviewing official”) before proposal submission. Guidelines to assist reviewing officials will be issued soon.
If the financial interests may reasonably be expected to have a direct and significant effect on the design, conduct, or reporting of the project, the disclosure will be referred to the standing Committee for Review of Positive Financial Disclosures. Financial interests not expected to have such an effect will require no further review.
Berkeley campus procedures have been reviewed by the Committee on Research and the Committee for Review of Positive Financial Disclosures. Please distribute the enclosed materials, which further define and implement the new procedures, as widely as possible within your units. If you have questions about implementation here at Berkeley, please contact the Sponsored Projects Office (2-0123 for NSF; 2-8114 for PHS).
Enclosures: Briefing sheet; SPAF addendum; Federal financial disclosure form
source: UC Berkeley CALmessages: https://calmessages.berkeley.edu/archives/message/16302