Requests from COI
For additional guidance on how to complete the requested COI disclosure form or task, please select the appropriate item below. All items (excluding the online KR Federal Disclosure and Certification, Ethics and Compliance Briefing for Researchers, and PHS/DOE Travel Log) should be submitted to coioc@research.uci.edu.
COI Deadlines & Meetings
Deadline to submit all necessary documents for review: First business day of the month
Committee meeting: Third Thursday of the month
Initial Disclosure (Do you have an outside financial interest?)
KR Federal Disclosure and Certification (Effective 10/31/24)
Who: "Investigator" on an active or proposed Public Health Service/National Institutes of Health, Department of Energy, National Science Foundation, National Aeronautics and Space Administration, or on a PHS, NSF, DOE, & NASA compliant project.
What: Complete the KR Federal Disclosure and Certification to disclose if you have any significant financial interests.
When:
- Prior to PHS, NSF, DOE, NASA compliant proposal submission
- At least annually for the duration of an active PHS/DOE compliant award
- Within 30 days of acquiring a new significant financial interest if you have never had one (answered "No" previously)
How: Click the above "KR Federal Disclosure and Certification" link. Answer the first two yes/no questions about whether you have a significant financial interests related to your institutional responsibilities and click "submit". The third question relates to malign foreign talent recruitment programs (if you have any questions, contact or-rsie@uci.edu).
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS, NSF, DOE, NASA, or proposed for such funding, which may include, for example, collaborators or consultants.
- Significant Financial Interests (includes foreign and domestic interests): Do you, your spouse/registered domestic partner, and/or dependent children have any of the following Significant Financial Interests (including Significant Financial Interests in foreign institutions of higher education and foreign government agencies) related to your Institutional Responsibilities?
- Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
- Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
- Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
- Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
- Any intellectual property rights and interest excluding those assigned to UC Regents
- Note: If you are an active PHS or DOE compliant Investigator, sponsored and reimbursed travel is considered a SFI that needs to be disclosed so you are also required to submit travel disclosures through the PHS/DOE Travel Log within 30 days of the new significant financial interest.
- Institutional Responsibilities: include an Investigator’s teaching/education, research, outreach, clinical service, and University and public service on behalf of the University of California and directly related to those credentials, expertise and achievements upon which the Investigator’s University of California campus position is based.
Additional Resources:
Update: Two new fillable DocuSign versions of the Form 700U available.
Form 700U PDF (still requires DocuSign signature)
Who: Principal Investigator or Co-Principal Investigator on a non-governmental sponsored research contract, grant, gift, or certain incoming material transfer agreement (see list of 700U exemptions).
What: Complete California State Disclosure Form 700U to determine if you have any disclosable financial interests per their policy.
When: Prior to release of an award; with a renewal (extension of time and money of the original award)
How: Complete the Form 700U about any financial interests in the non-governmental sponsor.
- Sponsored Research Agreement
- If know it will be funded during proposal submission (ex. industry clinical trial)- upload in KR Proposal Development.
- If do not know whether will be funded at proposal submission- Contracts & Grants Officer will request when awarded.
- Gift- submit with gift documentation to University Advancement.
- Material Transfer Agreement- If the principal investigator of a Material Transfer, responds “Yes” to questions 16-18 on the UCI Materials Transfer Agreement form, then the principal investigator must submit the State of California’s Statement of Economic Interest for Principal Investigators (Form 700U). The state disclosure requirement for principal investigators also applies to co-principal investigators.
Tips:
- Principal Investigator Only Form 700U (for cases when the PI completes the entire form)
- In the DocuSign PowerForm Signer Information page, enter the PI's name and UCI email address in the first two text boxes.
- (Optional) Enter a Department Administrator name and UCI email address in the last two text boxes if they should also receive a copy of the completed Form 700U
- In the DocuSign PowerForm Signer Information page, enter the PI's name and UCI email address in the first two text boxes.
- Department Administrator/Delegate and PI Form 700U (for cases when a department administrator or other delegate will complete the first sections of the form before sending it to the PI to complete the financial interest section and sign)
- In the DocuSign PowerForm Signer Information page, enter the Department Administrator’s name and UCI email address in the first two text boxes and enter the PI’s name and UCI email address in the last two text boxes.
- After the Department Administrator completes the top portion and sections 1 & 2, the form will route to the PI to complete and sign the Form 700U.
- Amount of Funding- check "Estimated" in case the amount may change
- Section 3- these questions refer to your personal financial interests in the sponsor/donor. Please exclude any income or gifts from the sponsor/donor paid to UCI because those are considered part of your UCI employment.
- Material Transfer Agreement
- Under Section 1: Please enter the name of the entity you are receiving a material transfer from and the estimated dollar amount of the materials (if not known, please indicate “research materials”).
- Under Section 2: Check “Initial” and enter the date you expect to start the research.
- Under Section 3: Please indicate whether or not you have any financial interests in the entity.
Additional Resources:
Form 800SR- non-UCI PHS/DOE Investigators
Who: If you are non-UCI Investigator participating in a UCI Public Health Service/National Institutes of Health, Department of Energy or PHS/DOE UCI out-going subaward without a PHS/DOE compliant policy
What: Annual disclosure to determine if you have any significant financial interests to the PHS/DOE compliant study.
When: Prior to PHS/DOE compliant proposal submission, at least annually for the duration of an active PHS/DOE compliant award, and within 30 days of acquiring a new significant financial interest.
How: Complete the appropriate disclosure form and submit with your subaward package submission or upload in KR Proposal Development with the proposal application.
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the purpose (DOE only), design, conduct, or reporting of research funded by PHS/DOE, or proposed for such funding, which may include, for example, collaborators or consultants. Note: DOE has discretion to expand this definition
- Significant Financial Interests (includes foreign and domestic interests): Do you, your spouse/registered domestic partner, and/or dependent children have any of the following Significant Financial Interests (including Significant Financial Interests in foreign institutions of higher education and foreign government agencies) related to this PHS/DOE compliant project?
- Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
- Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
- Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
- Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
Additional Resources:
Form 900SR- non-UCI NSF/ & NASA (effective 12/1/23) Investigators
Who: If you are non-UCI researcher participating in a UCI National Science Foundation or National Aeronautics and Space Administration compliant study or NSF/NASA UCI out-going subaward without its own NSF/NASA compliant policy
What: Disclosure to determine if you have any related significant financial interests.
When: Prior to NSF/NASA compliant proposal submission and after acquiring a new significant financial interest.
How: Complete the appropriate disclosure form and submit with your subaward package submission or upload in KR Proposal Development with the proposal application.
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by NSF/NASA, or proposed for such funding, which may include, for example, collaborators or consultants.
- Significant Financial Interests (includes foreign and domestic interests): Do you, your spouse/registered domestic partner, and/or dependent children have any of the following Significant Financial Interests (including Significant Financial Interests in foreign institutions of higher education and foreign government agencies) related to this NSF/NASA compliant 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, venture or other capital financing, 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 UC Regents)
- Total income or payment of services received over the past 12 months exceeding $10,000
Additional Resources:
Who: "Investigator" on an active or proposed Public Health Service/National Institutes of Health, Department of Energy or on a PHS/DOE compliant project.
What: Complete the PHS/DOE Travel Log to disclose all sponsored and reimbursed travel.
Exclude:
- Travel that is reimbursed or sponsored by a US Federal, state, local government agency, a domestic Institution of higher education, or a research institute affiliated with an Institution of higher education within US
- Sponsored or reimbursed travel for the Investigator's spouse/registered domestic partner and/or dependent children
- PHS only- Travel that is reimbursed or sponsored by an academic teaching hospital or medical center
When:
- Prior to PHS/DOE compliant proposal submission
- At least annually for the duration of an active PHS/DOE compliant award
- Within 30 days of acquiring a new significant financial interest if you have never had one (answered "No" previously)
How: Click the above "PHS/DOE Travel Log" link. Provide the basic information required about the trip and click "submit".
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the purpose (DOE only), design, conduct, or reporting of research funded by PHS/DOE, or proposed for such funding, which may include, for example, collaborators or consultants.
Additional Resources:
COI Addendum (Details about your outside financial interests)
Who: Investigator on active or proposed PHS/DOE compliant study who has a positive KR Federal Disclosure and Certification (answered "Yes" to question 1).
What: Complete Annual Form 810 to disclose the details of your significant financial interests for the COI Team's relatedness review as required by the PHS regulations or Department of Energy policy at least annually.
When: Initially at Just-in-Time or Notice of first PHS/DOE Award, then at least annually
How: Click the above "Annual Form 810" link and submit completed form to coioc@research.uci.edu. The COI Team will notify you if a COIOC review is required.
Tips:
- "Entity's Business Interests"- the more specific your description (if possible), the better chance that some of your PHS research will be considered unrelated
- "Percentage of Issued & Outstanding Shares"- if this is left blank, we contact you for this information
- If you have received consulting income over $10,000 in the past 12 months, make sure to include a copy of your consulting agreement with your 810 submission
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the purpose (DOE only), design, conduct, or reporting of research funded by PHS/DOE, or proposed for such funding, which may include, for example, collaborators or consultants. Note: DOE has discretion to expand this definition
- Significant Financial Interests (includes foreign and domestic interests): Do you, your spouse/registered domestic partner, and/or dependent children have any of the following Significant Financial Interests (including Significant Financial Interests in foreign institutions of higher education and foreign government agencies) related to your Institutional Responsibilities?
- Total income or payment of services received over the past 12 months and/or equity interest (includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in a publicly traded entity exceeding $5,000 when aggregated
- Total income or payment of services received over the past 12 months from a non-publicly traded entity exceeding $5,000
- Any equity interest (includes any stock, stock option, or other ownership interest) in a non-publicly traded entity
- Total payments received over the past 12 months for any intellectual property rights and interests (e.g., patent, copyright, assigned or licensed to a party other than the Regents) exceeding $5,000
- Note: If you are an active PHS compliant Investigator, sponsored and reimbursed travel is considered a SFI that needs to be disclosed so you are also required to submit travel disclosures through the PHS/DOE Travel Log within 30 days of the new significant financial interest.
- Institutional Responsibilities: include an Investigator’s teaching/education, research, outreach, clinical service, and University and public service on behalf of the University of California and directly related to those credentials, expertise and achievements upon which the Investigator’s University of California campus position is based.
Additional Resources:
COI Addendum Versions:
- Form 820- PHS/DOE compliant studies
- COI-1- IRB protocols, NSF/NASA (effective 12/1/23) compliant studies
- COI-1CA- Non-governmental sponsored studies (Form 700U)
- COI-3- Addendum for non-UCI researchers
Who: You disclosed a related significant/disclosable financial interest that requires COIOC review
What: COI Addendum is the main information the COIOC will review to determine if additional COI oversight is necessary or recommend it for approval
When: Prior to the release of an award or an IRB approval.
How: Complete the appropriate version of the COI Addendum and submit to coioc@research.uci.edu.
Tips:
- The first page of the COI Addendum includes tips to address the common COI concerns.
- Equity interests- make sure to include the percentage of issued and outstanding shares
- If you have received at least $10,000 in consulting income from the Entity, please attach a copy of your consulting agreement.
- COI Point Person is required for all new studies starting June 1, 2021 as a new UCI COI standard best practice (see the COI Point Person row for more information)
- COI Liaison is not required for all studies. We recommend it in cases where the Disclosing Individual has already engaged a non-conflicted, non-junior colleague to take on additional COI oversight responsibilities given the higher level COI concerns (such as the Disclosing Individual is the most senior person actively involved in many key aspects of the study that originally did not include any other non-conflicted peers of the Disclosing Individual's). Please indicate on the COI Addendum and attach the COI Liaison Acknowledgement Form. Note: We recommend including the COI Point Person responsibilities in the COI Liaison Acknowledgment Form to reduce how many additional individuals need to be involved. The COI Liaison should have more responsibilities than the COI Point Person's standard responsibilities.
Additional Resources:
Who: Principal Investigator or Co-Principal Investigator on a research gift with financial interests in the donor
What: Gift Addendum is the main information the COIOC will review to determine if additional COI oversight is necessary or recommend it for approval
When: Prior to the release of the gift funds.
How: Complete the Gift Addendum and submit to coioc@research.uci.edu.
Tips:
- Equity interests- make sure to include the percentage of issued and outstanding shares
Resources:
Who: If you were reviewed by the COIOC for the same financial interests for the same project last year (PHS/DOE compliant studies)
What: Simplified expedited review process to determine if there were any significant changes that would require a full committee review
When: Prior to release of continuation.
How: Complete the Expedited Form and submit to coioc@research.uci.edu
Tips:
- Please review your previously submitted disclosures carefully before answering the questions to the Expedited Form.
Other
Who: Study teams submitting industry clinical trials or similar types of projects with disclosing individual(s) that has a positive 700U and/or meets IRB disclosure thresholds.
What: This procedure should happen before or concurrently with the study team’s preparation for the contract negotiation by the Clinical Trial Contracts team. For more information regarding the Clinical Trial Contracts Negotiation procedure, please refer to their website. There are two conflict of interest policies that apply to industry clinical trials, State Law and IRB COI, that require disclosures of financial interests.
When: Required prior to IRB final approval and the execution of the contract
How: As the study team starts the application process, the Lead Researcher or study team coordinator should check with all study team members to determine if there will be a positive conflict of interest disclosure that would benefit from this earlier COI review process.
- IRB COI: Study team submits the KR Protocols (KRP) application for IRB review. KR Protocols application includes a financial interest disclosure question for all research personnel.
-
- UCI is relying on non-UCI IRB review: COIOC clearance or approval required before IRB Staff's administrative review to issue formal "Clearance to cede" to a non-UCI IRB.
- State Law: Attach DocuSigned Form 700U(s) from Principal Investigator and if applicable, Co-Principal Investigator, in the initial COI Notification Email and also upload the DocuSigned 700U(s) to KR Proposal Development (KR PD)
Procedure:
The process below is separate from the Clinical Trial Contracts Negotiation and is specific to COI procedure for Clinical Trial Study(s). For more information regarding the Clinical Trial Contracts procedure, please refer to their website.
- Initiate KRP application to generate the KRP number with the following sections as complete and accurate as possible before notifying the COI Team (KRP application does not need to be submitted prior to COI notification
- Study Team
- List of all known study team member(s)
- Disclosure of study team member(s)
- Responsibilities/duties of the study team member(s)
- Project description
- Principal Investigator/ Lead Researcher
- Funding
- Research Procedures / Study Design
- Medical Devices (if applicable)
- Study Team
- Collect the DocuSigned Form 700U(s) from the Principal Investigator and if applicable, Co-Principal Investigator
- Email COIOC@uci.edu with Master Protocol and DocuSigned Form 700U(s) attached. Include in the email the name of the Administrative contact assigned to the study.
-
- CCR: will indicate designated team (or specific member) involved in the administrative side of the study.
- Stem Center: will indicate designated team (or specific member) involved in the study with additional cc to Stem Center shared email.
This procedure should happen before or concurrently with the study team’s preparation for the contract negotiation by the by the Clinical Trial Contracts team.
Forms:
- Form 700U
- COI Addendum (COI-1)
- Non-UCI Researchers- Non-UCI COI Addendum (COI-3)
Who: As of June 1, 2021, all individuals on new studies reviewed by the Conflict of Interest Oversight Committee
What: Disclosing Individual must disclose their related financial interests to the study team working on that related project and identify a COI Point Person.
When: Required for Conflict of Interest Oversight Committee review
How: Submit a copy of the complete email (s) sent disclosing the related financial interest and the identified COI Point Person (who is copied on the email) with the COI Addendum (see Templates). This serves to document that the research team and the chosen COI Point Person are aware of the related financial interest and the identification of the COI Point Person.
Key definitions:
- COI Point Person: an UCI non-conflicted individual that is the same level or higher to the Disclosing Individual that is aware of the related financial interest and has been identified through email to the study team as the person to contact with any COI related questions or concerns.
- COI Liaison: an UCI non-conflicted individual that is peer-level or higher to the Disclosing Individual, who will provide additional COI oversight for the project by taking on additional responsibilities. In some cases, this COI Liaison's responsibilities may include the COI Point Person's responsibilities. Examples of some of the tasks the COI Liaison may participate in to provide additional COI oversight include but are not limited to:
- Data collection
- Access to project data
- Data analysis
- Data reporting
- Study design
- Review of reports
- Co-supervising students (undergraduate, graduate, and postdoctoral students)
- Disclosing Individual: individual with financial interest being reviewed by the COIOC
Possible COI Point Person:
- Disclosing Individual is is not the PI
- If the PI is non-conflicted and of equal or higher rank to the DI, they can serve as the COI Point Person.
- Disclosing Individual is the PI, but there is a non-conflicted investigator of equal or higher rank on the project
- The non-conflicted investigator that is of equal or higher rank to the DI can serve as the COI Point Person.
- Disclosing Individual is the PI and highest ranking individual on the project
- Identify a non-conflicted individual of equal or higher rank who can serve as the COI Point Person for the study team. The Point Person should have knowledge of the research subject matter. This can be the department chair or a similar leadership role. They would not need to be added to the project.
- COI Liaison has been identified for the project
- Include the responsibilities of the COI Point Person on the COI Liaison Acknowledgment Form to have this individual assume both roles. The COI Liaison must have additional responsibilities beyond the standard COI Point Person responsibilities.
If the Disclosing Individual has difficulty finding an appropriate COI Point Person, please contact the COI Team at coioc@research.uci.edu.
COI Liaison Acknowledgement Form
Who: (Optional) Disclosing Individuals who determined they have a higher level COI risk can identify a non-conflicted, equal rank or higher researcher to provide additional COI oversight.
What: COI Liaison Acknowledgment Form documents and confirms the person identified as the COI Liaison in the COI Addendum is aware of and accepts their specific COI oversight responsibilities.
When: Collected along with the COI Addendum for the COIOC review when the Disclosing Individual indicates there is a COI Liaison.
How: Submit a copy of the signed COI Liaison Acknowledgement Form with the COI Addendum submission to coioc@research.edu. In cases where disclosure to the study team and identification of a COI contact is required, include the description of the COI Liaison's responsibilities in the email (see COI Liaison Email Templates).
Key definitions:
- COI Liaison: a non-conflicted individual that is peer-level or higher to the Disclosing Individual, who will provide additional COI oversight for the project by taking on additional responsibilities. In some case, this COI Liaison may be the same individual identified as the COI Point Person for the study. Examples of some tasks the COI Liaison may participate in to provide additional COI oversight include but are not limited to:
- Data collection
- Access to project data
- Data analysis
- Data reporting
- Study design
- Review of reports
- Co-supervising students (undergraduate, graduate, and postdoctoral students)
- COI Point Person: a non-conflicted individual that is the same level or higher to the Disclosing Individual that is aware of the related financial interest and has been identified through email to the study team as the person to contact with any COI related questions or concerns.
- Disclosing Individual: individual with financial interest being reviewed by the COIOC
Tips:
- Make the COI Liaison also the COI Point Person by including the COI Point Person responsibilities (study team should contact this individual if they have any COI related questions or concerns) in the COI Liaison Acknowledgement Form.
Resources:
Ethics and Compliance Briefing for Researchers
Who: "Investigator" on an active or proposed Public Health Service/National Institutes of Health, Department of Energy or on a PHS/DOE compliant project.
What: Complete the UC Ethics and Compliance Briefing for Researchers (ECBR) at least every 2 years.
When:
- Prior to PHS/DOE compliant award
- At least every two years for the duration of an active PHS compliant award
How: Click the above "Ethics and Compliance Briefing for Researchers" link.
Key definitions:
- Investigator: include the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by PHS/DOE, or proposed for such funding, which may include, for example, collaborators or consultants. Note: DOE has discretion to expand this definition.
Additional Resources:
The Key Personnel section in the KR Proposal Development (KR PD) collects information about UCI researchers for two processes: Federal Proposal Review for Research Security & International Engagement (RSIE) and Conflict of Interest in Research for federal sponsors/prime sponsors. It is important to complete this section correctly so that the system can electronically trigger the processes as necessary.
Note: Non-UCI researchers should not be included in the KR PD Personnel tab.
KR PD Personnel Roles:
- Principal Investigator, PI/Contact, PI/Multiple, Co-PI, Key Person: This UCI individual will be sent an email with a custom link to the RSIE questionnaire they need to complete prior to the proposal being submitted to workflow. In addition, if the federal sponsor/prime sponsor has a conflict of interest policy (PHS/NSF/DOE/NASA), they also must have a current KR COI Annual Disclosure on file prior to proposal submission.
- Other Significant Contrib. (Contributor)- available February 28, 2024: Use this KR PD Personnel role when an UCI individual is required by the federal sponsor to submit a biographical sketch and other/current & pending support but does not meet the COI definition of an Investigator. This individual will be sent an email with a custom link to the RSIE questionnaire they need to complete prior to the proposal being submitted to workflow. No COI disclosure requirements.
- Investigator: This UCI individual is responsible for the design, conduct, or reporting of a research project with a federal sponsor or prime sponsor with a conflict of interest policy (PHS/NSF/DOE/NASA) but was not required by the federal sponsor to submit a biographical sketch or other/current & pending support. These UCI individuals must have a current KR COI Annual Disclosure on file prior to proposal submission. No RSIE questionnaire required.
| Federal Proposal Review Does the Federal sponsor/prime sponsor require a biographical sketch from this individual? | Conflict of Interest Is the individual an “Investigator” (responsible for the design, conduct, or reporting of the project)? | KR PD Personnel Role(s) Which KR PD Personnel Role should be used for that individual? |
|---|---|---|
| Yes | Yes | Principal Investigator, PI/Contract, PI/Multiple, Co-PI, or Key Person |
| Yes | No | Other Significant Contrib. (Contributor) (available 2/28/24) |
| No | Yes | Federal sponsor/prime sponsor with COI Policy (PHS, DOE, NSF, and NASA): Investigator |
| No | Yes | Federal sponsor/prime sponsor without a COI Policy: Do not include the individual in the KR PD Personnel tab |
| No | No | Do not include the individual in the KR PD Personnel tab |