DOE Financial Disclosure

The U.S. Department of Energy (DOE) requires disclosure of significant financial interests by investigators who participate in DOE or National Nuclear Security Administration (NNSA) funded research either directly or by subaward. For more information, see DOE Financial Disclosure Guidance.

Proposal Stage

At the proposal stage covered individuals must fill out the Conflict of Interest screening questions in Phoebe Proposal on behalf of all covered personnel that will be involved in the project. For this purpose, “covered individuals” are defined as: the principal investigator (PI), project director (PD), co-principal investigator (Co-PI), co-project director (Co-PD), project manager, any persons designated in the applicable notice of funding (NOFO), and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager and contributes in a substantive, meaningful way to the development or execution of the scope of work of a project funded by DOE.

If disclosure is required but the PI cannot access the screening questions in Phoebe, the PI will need to complete the DOE Financial Interest Screening Questions Form on behalf of all investigators involved in the project and upload this form in Phoebe Proposal.

Note: If any investigator prompts the PI to respond “yes” to any of the screening questions, the investigator will be required to complete and submit the DOE Financial Disclosure Form to the COI Office at coi-team@berkeley.edu for review prior to proposal submission.

Subrecipients: If subrecipients are included in the proposal, the authorized official of each subrecipient will need to complete the most current Subrecipient Commitment Form and answer financial interest questions on behalf of all subrecipient investigators named in the Berkeley proposal. Note: A subaward cannot be issued to a subrecipient that does not have a DOE-compliant COI policy in place.

Award Stage

If any covered individual prompted the PI to answer “yes” to any of the screening questions at the proposal stage, the individual will be required to complete and submit the DOE Financial Disclosure Form to the COI Office at coi-team@berkeley.edu prior to the award being released.

If the PI responded, “no,” to all the screening questions at the proposal stage then nothing more is required unless the PI’s responses to the screening questions were obtained more than 12 months prior to award receipt. If the questions were answered more than 12 months earlier, the PI will need to submit an updated DOE Financial Interest Screening Questions Form on behalf of all investigators currently involved in the project.

Training: All covered individuals are required to take DOE-compliant training prior to engaging in DOE or NNSA funded research, and at least every two years during the life of the project.

During Life of Award

The PI is required to complete the DOE Financial Interest Screening Questions Form at least annually on behalf of all covered individuals involved in the project when the PI:

  • Submits the Continuation Application (non-competitive application) or progress report
  • Request a no-cost time extension,
  • Adds new covered individuals to the project, and/or
  • Becomes aware that a covered individual that is involved in the project has acquired or discovered a new significant financial interest. This must be reported within 15 days.

If the DOE Financial Interest Screening Questions Form provided by the PI at any point listed above includes a “yes” response, then the covered individual that prompted the “yes” response will be required to complete the DOE Financial Disclosure Form and email it to their SPO CGO.

Covered individuals must disclose new Significant Financial Interests within 15 days of acquiring the new interest by submitting a DOE Financial Disclosure Form by email to their SPO CGO.

Training: All Investigators are required to take DOE-compliant training prior to engaging in DOE or NNSA funded research, and every two years during the life of the project.

Forms

NOTE: Please use Adobe Acrobat or Reader to fill out PDF forms. (If you have difficulty filling out a form, please download the form to a local computer before filling it out.)

Resources

Related information