PHS Financial Disclosure
The Public Health Service (PHS) requires disclosure of significant financial interests by investigators who participate in PHS-funded research either directly or by subaward. Other agencies have adopted the PHS requirements. For more information, see PHS Financial Disclosure Guidance.
At the proposal stage the Principal Investigator (PI) must fill out the Conflict of Interest screening questions in Phoebe Proposal on behalf of all investigators that will be involved in the project. For this purpose, an “investigator” is defined as: the Principal Investigator (PI) and any other person/s (regardless of title or position) that the PI identifies as independently responsible for the design, conduct, or reporting of the research.
If disclosure is required but the PI cannot access the screening questions in Phoebe, the PI will need to complete the PHS 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 PHS Financial Disclosure Form to the COI Office at email@example.com for review prior to the award being released.
Subrecipients: If subrecipients are included in the proposal, the authorized official of each FDP 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 PHS compliant COI policy in place.
If any investigator prompted the PI to answer “yes” to any of the screening questions at the proposal stage, the investigator will be required to complete and submit the PHS Financial Disclosure Form to the COI Office at firstname.lastname@example.org 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 PHS Financial Interest Screening Questions Form on behalf of all investigators currently involved in the project.
Training: All Investigators are required to take PHS-compliant training prior to engaging in PHS-funded research.
During Life of Award
The PI is required to complete the PHS Financial Interest Screening Questions Form at least annually on behalf of all investigators involved in the project when the PI:
- Submits the progress report/non-competing continuation (RPPR),
- Requests a no-cost time extension,
- Adds new investigators to the project, and/or
- Becomes aware that an investigator that is involved in the project has acquired or discovered a new significant financial interest. (This must be reported within 30 days.)
If the PHS Financial Interest Screening Questions Form provided by the PI at any point listed above includes a “yes” response, then the investigator that prompted the “yes” response will be required to complete the PHS Financial Disclosure Form and email it to their SPO CGO.
Investigators must disclose new Significant Financial Interests within 30 days of acquiring the new interest by submitting a PHS Financial Disclosure Form by email to their SPO CGO.
Training: All Investigators are required to take PHS-compliant training while engaging in PHS-funded research.
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.)
- PHS Financial Interest Screening Questions Form (if not completed in Phoebe at proposal stage, and annually or at the Progress Report stage)
- PHS Financial Disclosure Form (if yes to any screening questions)
- PHS Financial Disclosure: Significant Financial Interests - Entity (optional attachment to PHS Financial Disclosure Form)