Conflict of Interest

The University of California, Santa Cruz, has high standards for faculty conduct, including the conduct of research, as discussed in the University of California Faculty Handbook and the Academic Personnel Policy Manual. All UCSC investigators are expected to carry out research consistent with these standards

Even when these high standards have been met, however, conflicts of interest or perceptions of conflicts may still occur when there is a convergence of an investigator's private interests with his or her research interests, such that an independent observer might reasonably question whether the investigator's professional actions or decisions are improperly influenced by considerations of personal financial gain. Such conflicts are common in modern research universities and do not necessarily impugn the character or actions of any individual.

The university is obligated by external requirements to require disclosure of personal interests for extramural funding. Such disclosure processes are the most widely accepted method for identifying and managing actual or potential conflicts of interest related to sponsored projects in public institutions. The Conflict of Interest Review Committee (COIRC) has been established to comply with regulations that require review of such potential conflicts. When the university determines that a positive disclosure might reasonably appear to be directly and significantly affected by the sponsored project, the university will take steps either to manage or to eliminate the conflict.

The COIRC reviews disclosable financial interests related to their extramural funding submissions, as well as positive conflict of interest disclosures reported in human subjects research on the IRB application.

Types of Required Conflict of Interest Forms

PHS(NIH):

A form 900 is required annually for all grants sponsored by NIH, or for funding originally granted by NIH through a pass-through agency. Forms must be collected from the PI and all UCSC Key Personnel who meet the PHS definition. In addition to NIH, the form 900 is also required for the following agencies;

  • Agency for Health Care Research & Quality
  • Agency for Toxic Substances and Disease Registry
  • Alliance for Lupus Research
  • American Asthma Foundation
  • American Cancer Society
  • American Foundation for Suicide Prevention
  • American Heart Association
  • American Lung Association
  • Arthritis Foundation
  • Centers for Disease Control and Prevention
  • CurePSP
  • Food and Drug Administration
  • Harrington Discovery Institute
  • Health Resources and Services Administration
  • Indian Health Service
  • Juvenile Diabetes Research Foundation
  • Lupus Foundation of America
  • Office of Global Affairs
  • Office of the Assistant Secretary for Health
  • Office of the Assistant Secretary for Preparedness and Response
  • Patient-Centered Outcomes Research Institute
  • Substance Abuse and Mental Health Services Administration
  • Susan G. Komen for the Cure

Non-Governmental Agencies:

A form 700 is required, printed and physically signed in ink by the PI, for research grants applications to any type of entity (Sponsor and/or Prime Sponsor) except for the following;

  • A governmental agency
  • A non-profit, tax-exempt educational institution
  • an entity listed on the exemption list (here)

NSF:

A form 800 is required for all grants sponsored by NSF, or for funding originally granted by NSF through a pass-through agency. Forms must be collected from the PI and all UCSC Key Personnel who meet the NSF definition. In addition to NSF, the form 800 is also required for the following agencies;

  • California Institure for Regenerative Medicine

 

Subawards:

A subaward COI form is required to be collected from the UCSC PI for all entities (except governmental and non-profit, tax-exempt educational institutions) that will be a subrecipient of grant/contract funds received by UCSC.