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Disclosure Procedures

UCI Procedures for Disclosure and Review of Principal Investigator's Financial Interests in Nongovernmental Sponsors of Research

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In consultation with the Academic Senate Committee on Research and the Vice Chancellor-Research, the Chancellor established the following procedures to implement the Policy on Disclosure of Principal Investigator's Financial Interests in Nongovernmental Sponsors of Research. At UCI, the Vice Chancellor-Research has been delegated responsibility for its implementation.

I. Disclosure of Financial Interests

  1. Form 700-U, "Principal Investigator's Statement of Economic Interests" is to be completed by principal investigators for all research projects which have been or will be funded, in whole or in part:
    1. Through a contract or grant of $250 or more from a non-governmental entity; or
    2. By a gift from a non-governmental entity which is earmarked by the donor for a specific research project or a specific principal investigator, provided the amount of the gift, or the aggregate over a 12-month period from the same donor, is $250 or more.

    It should be understood that the $250 figure and use of Form 700-U has been mandated by the State of California Fair Political Practices Commission; that the information disclosed will be available to public scrutiny under the law; and that principal investigators must declare the statement to be true under penalty of perjury. A list of research sponsors that are exempt from this requirement has been approved by the State of California Fair Political Practices Commission.

  2. Within this context, the form must be filed whenever:
    1. The Principal Investigator applies for or requests renewal of a contract or grant from a private sponsor;
    2. Whenever a gift is specified by a donor for a particular investigator or for a specific research project for which he or she is responsible; and
    3. Within 90 days after the research project is completed or the gift funds are exhausted.
  3. To file the form (submit original):
    1. Attach it to the UCI Administrative Approval Form when application is made to a private sponsor for support of a research project;
    2. Attach it to the Gift Acceptance Form when a gift is restricted to a particular investigator or specific research project for which the investigator is responsible;
    3. If no proposal is required for renewal of contract or grant, the disclosure form must be filed prior to acceptance of the renewal award;
    4. The Office of Sponsored Projects Administration (SPA) will remind the Principal Investigator to file the form within 90 days after the termination of the contract;
    5. The Accounting Office will advise SPA when the gift funds are exhausted and SPA will request the Principal Investigator to file Form 700-U.
  4. Completed forms are kept on file at the Office of Research Administration for the requisite retention period.

II. Review of Financial Interests and the Proposed Project

  1. When the disclosure indicates a financial interest exists, the Vice Chancellor-Research (VCR) will request an independent substantive review by the Conflict of Interest Oversight Committee (COIOC), which has been appointed for this purpose by the VCR. University policy requires completion of the disclosure statement, and approval by the COIOC and VCR as necessary, prior to acceptance of any gift, grant, or contract from a nonexempt, nongovernmental entity.
    1. Timely submission of the disclosure statement and other material requested by the COIOC will allow fair and thorough consideration of those cases where a potential conflict of interest exists, and will prevent unnecessary delays in receipt of private funding. To facilitate committee review of the financial interest and the project, supplemental questionnaire, the Investigator's Disclosure of Economic Interests Addendum form has been developed to address the principles set forth in the University Guidelines for reviewing financial interests.1
    2. The COIOC will consider the research project in the light of traditionally held principles of ethical conduct and academic freedom. The COIOC will evaluate whether: there is sufficient separation of University and private interests, the proposed research is appropriate to the University, the teaching and research environment is open, freedom to publish and to disseminate research results is preserved, the University's rights are protected, the University's facilities and resources are used appropriately, and that the University receives proper compensation for their use. The committee shall, in its written documentation of the review, address each of the principles set forth in the Guidelines and establish the basis for its recommendation.
    3. The committee may consult with administrators, faculty, and others involved in the research and review process and the academic discipline in question. It may also invite individuals with competence in special areas to assist in the review process which require expertise beyond, or in addition to, that available to the committee.
    4. The COIOC will provide a recommendation to the Vice Chancellor-Research whether funding for the research project should be accepted and, if so, whether any modifications or conditions are needed. The Vice Chancellor-Research will render a final decision regarding the acceptability of the proposed contract, grant, or gift under University policy.
  2. Records of disclosure statements, the review committees' recommendations, and the written decisions resulting from the independent review process will be maintained by the COIOC Administrator in the Office of Research Administration.

1 The Investigator's Disclosure of Economic Interests Addendum replaced the Federal Description form in August of 2002. The Investigator's Disclosure of Economic Interests Addendum also replaced the State Application and Completion forms and the IRB disclosure form. The new form aimed to alleviate administrative burdens.