COI Disclosure Requirements Comparison

Guidance

The University recognizes that outside financial interests can facilitate opportunities for innovation, collaboration, and support. A conflict of interest is a situation in which an investigator’s outside financial interest(s) or obligation(s) have the potential, whether real or perceived, to bias a research project or cause harm to human subjects participating in a research project. Federal, State, and University regulations and policies requiring financial disclosure and review were implemented to address those instances when the outside financial interests may bias or appear to bias the research. The chart below provides a comparison overview of the financial disclosure requirements.

Disclosing individuals must disclose their financial interests received within the 12 months prior to disclosure submission including the financial interests of his/her spouse/registered domestic partner, and/or dependent children. All positive disclosures must be approved prior to acceptance of the award or additional funding, to expenditure of funds.

The chart is also available as a PDF.

Related information

Comparison Chart

Category State Law NASA, NSF and Other Non-PHS Federal Public Health Service
Reporting Triggers
  • Research contract/grant from a non-governmental entity
  • Research Gift earmarked for a specific individual or a specific research project
  • Material Transfer Agreement
  • Data Use Agreement
Note: Exclude all exempt sponsors on FPPC approved list and all non-profit, tax-exempt educational institutions. However, researchers must disclose for the prime sponsor if the educational institution received its funds from a non-governmental entity.
  • NSF research contract/grant
  • Non-governmental entity which flows down NSF funds
  • California Institute for Regenerative Medicine (CIRM) grant
  • UC Research Programs (HIV/AIDS, breast cancer, and tobacco-related disease)
Note: Exclude Phase 1 SBIR or STTR grants.
  • PHS research contract/grant
  • Non-governmental entity which flows down PHS funds
  • Research funding from organizations that follow PHS disclosure requirements (e.g., American Cancer Society, American Heart Association). See agency list
Note: Exclude Phase 1 SBIR or STTR grants.
Who UCB Principal Investigator and co-Principal Investigator, if applicable UCB Investigator(s) (individuals responsible for the design, conduct, or reporting of the funded research project) UCB Investigator(s) (individuals responsible for the design, conduct, or reporting of the funded research project)
What to Disclose A financial interest in the non-governmental sponsor of the research including:
  • Income ≥ $500
  • Investments ≥ $2,000
  • Director, Officer, Employee, Partner, Trustee, Consultant or Management position (paid or unpaid)
  • Loan Balances ≥ $500
  • Personal Gifts valued at ≥ $50
  • Travel Reimbursements
 A significant financial interest related to the research project including:
  • Income > $10,000 (excluding income from seminars, lectures, teaching engagements, or service on advisory committees or review panels for public or nonprofit entities)
  • Equity interest > $10,000 or 5%
  • Intellectual Property interest in a patent, patent application, or copyright of a software (excluding intellectual property owned by the UC)
A significant financial interest related to the investigator’s institutional responsibilities including:
  • If publicly traded entity, total value of compensation > $5,000 or equity interest > $5,000
  • If non-publicly traded entity, total value of compensation > $5,000 or any equity interest, regardless of value
  • Income received related to intellectual property > $5,000 (excluding intellectual property owned by the UC)
  • Reimbursed or sponsored travel > $5,000 (per NIH) (excluding (1) travel funded by a US government agency, a US university, academic medical center, or affiliated research institute; and (2) sponsored or reimbursed travel for the Investigator’s immediate family)
When to Disclose
  • With the initial research contract/grant proposal
  • With the initial gift award
  • With the MTA/DUA request
  • With renewal award (additional funding intended to extend or results in extension of a project beyond the originally approved project period)
  • With the initial proposal
  • When a new Investigator(s) is added
  • With any change in an investigator’s financial interest
  • With the initial and renewal proposals
  • With supplemental funding proposal
  • With non-competing continuation
  • With no cost time extension
  • When a new Investigator(s) is added
  • At least annually for duration of project
  • With any new significant financial interest (New significant financial interests must be reported within 30 days of acquiring or discovering the new SFI.)
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