Federal agencies and UCOP have expanded the definition of research support to include all paid or in-kind resources supporting a PI’s research program, whether the support is made through UC Santa Cruz or provided directly to the researcher. The resources on this page have been compiled to assist faculty and staff in navigating various disclosure requirements, including guidance on who must disclose, as well as when and how disclosures should be made.
PHS (NIH), DOE, and NIJ
The Public Health Service (PHS), Department of Energy (DOE), National Institute of Justice (NIJ) and agencies that follow PHS policy require investigators to disclose significant financial interests related to institutional responsibilities. The University of California defines institutional responsibilities as teaching/education, research, outreach, clinical service, and university and public service on behalf of the University of California which are in the course and scope of the investigator’s University of California appointment/employment.
Related policies
- Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought
- PHS Policy on Objectivity in Research
- PHS final rule, summary
- NIH FAQ
- NIH disclosure requirements clarification notice
- DOE COI Policy (12-2-2021)
- UC Conflict of interest policy for PHS (NIH) and DOE funded research
PHS definitions
| Term | Definition |
|---|---|
| Income | Includes salary, consulting fees, honoraria, paid authorship, income received related to intellectual property rights and interests, etc. not paid by or assigned to the UC Regents. |
| Investigator | Any personnel on a PHS or DOE funded project who is responsible for the design, conduct, or reporting of the research. |
| Institutional responsibilities | Defined as teaching/education, research, outreach, clinical service, training and university and public service, on behalf of UC Santa Cruz and directly related to those credentials, expertise and achievements upon which the investigator’s UC Santa Cruz position is based. |
| Financial interest | Anything of monetary value, whether that value can be easily determined or not, that is held by you, your spouse or registered domestic partner, and dependent children. |
| Significant financial interest | An interest related to the investigator’s institutional responsibilities may include but are not limited to: • income or honoraria received for activities such as providing expert testimony or consulting services, serving on a board of directors, scientific advisory board, committee, panel or commission sponsored by a for-profit or non-profit organization, including professional or scholarly societies; acting in an editorial capacity for a professional journal or reviewing journal manuscripts, book manuscripts, or grant or contract proposals for a non-profit or for-profit organization; accepting a position as a salaried employee outside the university or receiving royalty payments for intellectual property rights held by an entity other than The Regents; • holding stock or stock options in a company that is developing, manufacturing or selling products or providing services used in an investigator’s clinical practice, teaching, research, administrative or committee responsibilities; or • travel paid for or reimbursed by an outside entity that exceeds $5,000 per entity per 12 months. |
When to disclose
- At least annually through the life of a PHS or DOE-supported research grant/contract (including no-cost extension periods)
- With proposals (new, renewal, supplemental)
- Within 30 days of an investigator acquiring or discovering a new significant financial interest
- When a new investigator (see definition below in “Who must disclose”) joins an ongoing project
All positive disclosures must be reviewed and approved prior to acceptance of an award, award modification, or personnel change.
Who must disclose
All investigators, defined to include the project director/principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS. At the time of submitting a proposal, all investigators must submit disclosures for themselves and their spouses/registered domestic partners and dependent children.
What to disclose
- Income received from a publicly traded entity during the 12 months prior to disclosure which, when combined with the value of any equity interest you hold in the entity, exceeds $5,000.
- Income received from a non-publicly traded entity during the 12 months prior to disclosure that exceeds $5,000 OR any equity interest you hold in that entity.
- Income received from an entity, other than UC, for intellectual property rights and interests during the 12 months prior to disclosure that exceeds $5,000. This could include royalties for books, or license fees for software or technology you may have invented before you came to UC Santa Cruz.
- Travel paid for or reimbursed by a for-profit or non-profit entity, including professional organizations and foreign universities, that exceeds $5,000 per entity per 12 month period.
NSF & NASA
The National Science Foundation (NSF) and the National Aeronautics and Space Administration (NASA) require institutions to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced or eliminated prior to the expenditure of the award funds. All investigators submitting proposals to NSF or NASA, including when performing as subcontractors, must disclose significant financial interests for themselves, their spouses/registered domestic partners and dependent children.
Related policies
- NSF COI policy (1/30/2023)
- NASA COI policy (8/31/2023)
- UC Conflict of interest policy for NSF, NASA, and other UC-funded research
NSF definitions
| Term | Definition |
|---|---|
| Investigator | The principal investigator, co-principal investigators/co-project directors, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF. |
| Significant Financial Interest (SFI) | Anything of monetary value including but not limited to: • Salary, income, honoraria, royalties, dividends, consulting, loans, travel reimbursement, or other payment or consideration with value (e.g., equipment loans) from any business, public, or nonprofit entity exceeding $10,000 during the prior twelve months, aggregated for the investigator, spouse, and dependent child(ren). • Equity interest, venture, or other capital financing (stock, stock options, real estate, etc.) that exceeds $10,000 or 5% ownership. • Management position such as board member, director, officer, partner, or trustee held by the investigator. Intellectual property interest held by the investigator, spouse, and dependent child(ren) assigned or to be assigned to a party other than the Regent. |
| Related Financial Interest (RFI) | Work performed under a sponsored project, which results would appear to affect the investigator’s SFI. Examples of situations which are considered RFIs: • The results of the sponsored project being carried out by the investigator would be relevant to development, manufacturing, or improvement of product or service of an entity in which the investigator has a SFI. • The investigator has a financial interest in an entity which might manufacture or commercialize a drug, device, procedure, or any other product used in the project or that will predictably result from the project. • The investigator gets consulting income from a single entity that exceeded $10,000 during the prior twelve months and the financial interests of that entity, or the investigator’s financial interest related to consulting for that entity, would reasonably appear to be affected by the research to be conducted. |
When to disclose
- With proposals (new, renewal, supplemental).
- Whenever there is a change in an investigator’s financial interest.
- When a new investigator joins an ongoing project.
- Annually for existing financial interests.
All positive disclosures must be reviewed and approved prior to acceptance of an award, award modification, or personnel change.
Who must disclose
All investigators, defined to include the principal investigator, co-principal investigator(s), and any other person at the institution who is responsible for the design, conduct, or reporting of research or education activities funded or proposed for funding by NSF or NASA. The lead PI is responsible for accurately classifying the individuals on a project based on their roles that meet the definition of “investigator.”
What to disclose
- Salary, income honoraria, royalties, dividends, consulting, loans, travel reimbursement, or other payment for services over the past 12 months ≥ $5,000.
- Equity interest, venture, or other capital financing (stock, stock options, real estate, etc.) that exceeds $5,000 or 5% ownership.
- Receipt of payments for any intellectual property rights (e.g., patents, copyrights and royalties from such rights) ≥ $5,000.
- Management position such as board member, director, officer, partner, or trustee held by the investigator.
Non-governmental agencies
The State of California law requires the principal investigator and co-principal investigator to disclose financial interest on behalf of the investigator, the investigator’s spouse, registered domestic partner, and dependent child(ren):
- In the sponsor of a research project.
- The donor of a research gift.
- The provider of materials under a Material Transfer Agreement (MTA) when that sponsor, donor, or provider is a non-governmental source.
Disclosure is required for research grant applications to any type of entity (sponsor and/or prime sponsor) except for governmental agencies, non-profit, tax exempt educational institutions, and any entity listed on the exemption list. Per the State of California Fair Political Practices Commission (FPCC) regulations, the Form 700 can be submitted either with a physical ink signature or signed using UC Santa Cruz’s DocuSign service.
Related policies
Non-governmental agency definitions
| Term | Definition |
|---|---|
| Investment | Any financial interest in a business entity in which you, your spouse or registered domestic partner, or your dependent children have a direct, indirect, or beneficial interest totaling $2,000 or more. Reportable investments include stocks, bonds, warrants, and options, including those held in margin or brokerage accounts. (See Gov. Code Section 82034 and Regulation 18237.) |
| Income | A payment received, including but not limited to any salary, wage, advance, dividend, interest, rent, proceeds from any sale, gift, including any gift of food or beverage, loan forgiveness or payment of indebtedness received by the filer, reimbursement for expenses, per diem, or contribution to an insurance or pension program paid by any person other than an employer, and any community property interest in income of a spouse or registered domestic partner. Income also includes an outstanding loan. Income of an individual also includes a pro rata share of any income of any business entity or trust in which the individual, spouse, or registered domestic partner owns directly, indirectly, or beneficially, a 10% interest or greater. Income includes your gross income and your community property interest in your spouse’s or registered domestic partner’s gross income totaling $500 or more. Gross income is the total amount of income before deducting expenses, losses, or taxes. |
| Filer for form 700 | This form must be filed by all persons employed by UC or CSU who have principal responsibility for a research project if the project is to be funded or supported, in whole or in part, by a contract or grant (or other funds earmarked by the donor for a specific research project or for a specific researcher) from a nongovernmental entity. Reporting requirements are outlined in Regulation 18755. This regulation provides that research funding by certain nonprofit entities will not trigger disclosure. This regulation is available on the FPPC website. |
| Reporting period | For “initial” statements, before the final acceptance of the contract, grant, or gift, the filer must report investments in and business positions with the sponsor as of the date that the award is made, and income and gifts received from the sponsor within the 12 months prior to the date that the award is made. For “interim” statements, the filer must submit a statement within 30 days after the contract, grant, or gift is renewed that discloses reportable investments, income and business positions that the filer held or received during the period between the date the initial statement was filed and the date the project contract, grant, or gift was renewed. |
| Reportable loan | Loans received or outstanding are reportable if they total $500 or more from a single lender. Your community property interest in loans received by your spouse or registered domestic partner also must be reported. Loans from commercial lending institutions made in the lender’s regular course of business on terms available to members of the public without regard to your official status are not reportable. |
| Gift | Anything of value for which you have not provided equal or greater consideration to the donor. A gift is reportable if its fair market value is $50 or more. In addition, multiple gifts totaling $50 or more received from a reportable source must be reported. It is the acceptance of a gift, not the ultimate use to which it is put, that imposes your reporting obligation. Therefore you must report a gift even if you never used it or if you gave it away to another person. If the exact amount of a gift is not known, you must make a good faith estimate of the item’s fair market value. Listing the value of a gift as “over $50” or “value unknown” is not adequate disclosure. |
| Travel payments | Include advances and reimbursements for travel and related expenses, including lodging and meals. |
| Violations | Failure to file the required Statement of Economic Interests or failure to report a financial interest may subject a principal investigator to civil liability, including fines, as well as university discipline. (See Gov. Code Sections 81000- 91014.) |
| Privacy Information Notice | Information requested on all FPPC forms is used by the FPPC to administer and enforce the Political Reform Act (Gov. Code Sections 81000-91014 and Regulations 18110-18997). All information required by these forms is mandated by the Political Reform Act. Failure to provide all of the information required by the Act is a violation subject to administrative, criminal or civil prosecution. All reports and statements provided are public records open for public inspection and reproduction. If you have any questions regarding this privacy notice or how to access your personal information, please contact the FPPC at: General Counsel Fair Political Practices Commission 1102 Q Street, Suite 3000 Sacramento, CA 95811 (916) 322-5660 |
When to disclose
- With the initial proposal.
- With the initial gift award.
- With the MTA/DUA request.
- With requests for additional support.
All positive disclosures must be reviewed and approved prior to acceptance of the award or additional support.
Who must disclose
Principal investigator & co-principal investigator, if applicable.
What to disclose
- A business position with the sponsor or donor, such as a director, officer, partner, trustee, consultant, employee, or any other position of management.
- Investment or equity (ownership) interest in the sponsor or donor worth $2,000 or more.
- Income or loan from the sponsor or donor aggregating $500 or more.
- A gift from the sponsor or donor with a value of $50 or more. (A gift is anything of value for which you have not provided equal or greater consideration to the donor.)
- Payments either in advance, as reimbursement, or in-kind are reportable.
- Payment for travel from the sponsor or donor with a value of (a) $50 or more if a gift or (b) $500 or more if income (see note below).
Travel payments are gifts if you did not provide services which were equal to or greater in value than the payments received. Travel payments are income if you provided services which were equal to or greater in value than the payments received.
Small business (SBIR/STTR)
For Phase I of the Small Business Innovation Research (SBIR) (R43) and Small Business Technology Transfer (STTR) (R41) projects, the PI must complete a Non-governmental agency disclosure form to submit with the proposal. Phase I of both SBIR and STTR programs, when funded by a Public Health Service agency or the Department of Energy, are exempt from the federal requirements concerning disclosure of financial interests.
For Phase II of the SBIR (R44) and STTR (R42) projects, the PI and key personnel must complete a Non-governmental agency disclosure form and the relevant annual Federal disclosure (ORCOI).