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National Science Foundation (NSF) Policy

Effective: October 1995
The National Science Foundation (NSF) requires principal investigators and all other investigators responsible for the “design, conduct or reporting” of the NSF-funded research project or educational activities to disclose their significant financial interests related to the research project or educational activities.  Investigators must also disclose the financial interests of their spouses/registered domestic partners and dependent children.  UCI’s policy is consistent with the “Investigator Financial Disclosure Policy” of the NSF. 

This policy also applies to any proposal submitted to California Institute for Regenerative Medicine (CIRM), UC Discovery Grant Programs, UC Special Research Programs, and any other institutions whose proposal to any of the above sponsors includes a subaward to UCI.

When to Disclose:

  • Initial funding
  • New personnel added
  • Any change in an investigator’s financial interest

Definitions:

  • Investigator: Any individual responsible for the design, conduct, or reporting of the results of work performed or to be performed under the sponsored research or educational activities. Reporting includes authorship on any publications resulting from the research; it may include students, graduate and undergraduate, even if they are not paid from the project. "Investigator" includes the Principal Investigator, Co-Investigators, and any other individual (including personnel from other institutions) who has independent responsibility for accomplishing project objectives.  For more information, visit Identifying NSF Investigators.
    • For any non-UCI Investigators on the UCI proposal/award and any subrecipients following UCI's NSF COI policy, all individuals who meet the definition of an Investigator must complete the Form 900SR.
  • Related Financial Interest: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest. Consistent with federal regulations, the following examples are financial interests that are considered "related" to a sponsored project:
    • The Investigator is conducting a project where the results could be relevant to the development, manufacturing, or improvement of the products or services of the entity in which the investigator has a financial interest;
    • 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 has consulting income in his/her professional field that exceeded $10,000 from a single entity during the prior twelve months, where the financial interest of the entity or the Investigator would reasonably appear to be affected by the federally-sponsored research;
    • The Investigator has a financial interest in an entity and the sponsored project proposes to subcontract a portion of the work, or lease property, or make referral of participants to, or make purchases from the entity; or
    • The Investigator has a financial interest in an entity that is part of a consortium or that will otherwise participate in the sponsored project

 

Determining Significant Financial Interests

All Investigators must complete their Annual DIsclosure in KC COI.  Investigators with financial interests (excluding travel) will also need to complete the NSF Disclosure, which asks:

Do you, your spouse/registered domestic partner, and/or dependent children have any of the following financial interests related to your project?

  • Total income or payment of services received over the past 12 months exceeding $10,000
    • Includes salary, consultant payments, honoraria, royalty payments, dividends, loan or any other payments or consideration with value, including payments made to the University Health Sciences Compensation Plan). Please exclude income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities and income from service on advisory committees or review panels for public or nonprofit entities
  • Equity interest (e.g., stock, stock options, real estate, or any other investment or ownership interest in an entity exceeding $10,000 (current market value) or a 5% or greater ownership interest
  • Any intellectual property rights and interests (e.g., a patent, patent application, copyright of software assigned or licensed to a party other than the Regents)

If an investigator responds “No” to this question, then no further COIOC review is required.

If an investigator responds “Yes” to this question, then the investigator needs to complete the Addendum for All Positive Disclosures to be reviewed by the COIOC.

Forms

For Non-UCI Investigators following UCI's NSF COI Policy:

  • NSF Subrecipient/Non-UCI Investigator Disclosure (Form 900SR)
  • Addendum for Non-UCI Personnel (Form COI-3)

Guidance

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