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Non-governmental Sponsor (State Law)

Announcements

State of California law requires the Principal Investigator and Co-Principal Investigator (if applicable) of a research contract, grant, or gift from a non-governmental entity to disclose their financial interests and the financial interests of their spouse/registered domestic partner and/or dependent children in the sponsor unless it is on the exempt sponsors list.

700U Question Flowchart

When to Disclose:

  • Standard proposals: when the project is awarded
  • After the fact proposals: with proposal submission in Kuali Coeus (KC)
  • Joint 700U/IRB proposals: with New IRB Application (e-APP) submission

Procedures

Accurate responses to the KC and Institutional Review Board (IRB) questions will generate the applicable instructions to help identify when and how to submit the electronic copy of the Statement of Economic Interests for Principal Investigators (Form 700U). In addition to the electronic copy, the original, wet-ink signed Form 700U must be forwarded to the “COI Team, Zot: 7600” for record-keeping.

  • Standard Proposal- The Sponsored Projects Administration (SPA)/Industry Officer will send the Principal Investigator (and Co-Principal Investigator if applicable) an email request for the original and a scanned copy of the form once the proposal has been awarded. Please do not upload the Form 700U in KC.  The Conflict of Interest (COI) Team will contact the Principal Investigator and/or Co-Principal Investigator if additional forms are required.
  • After the Fact Proposal- Please upload a scanned copy of the Form 700U in KC along with the other proposal documents.  The COI Team will contact the Principal Investigator and/or Co-Principal Investigator if additional forms are required.
  • Joint 700U/IRB Proposal- Please upload a scanned copy of the Form 700U with the New IRB application. The COI Team will contact the Principal Investigator and/or Co-Principal Investigator if additional forms are required.
    • Recommendations:
      • Create and save the KC proposal before submitting the New IRB Application because the New IRB Application will request the KC proposal number.
      • Submit the KC and IRB applications for a project around the same time to initiate both processes and avoid delays in processing if possible.

Determining Disclosable Financial Interests

The Principal Investigator must submit the Statement of Economic Interests for Principal Investigators (Form 700U), which asks questions regarding financial interests the Principal Investigator, Principal Investigator’s spouse/registered domestic partner and dependent children may have in the sponsor at the award stage.  The state disclosure requirement for Principal Investigators also applies to Co-Principal Investigators.

  • If the Principal Investigator, Principal Investigator’s spouse/registered domestic partner and dependent children indicate “No” for all the questions in Section 3 (Filer Information), then the Principal Investigator only needs to submit the Statement of Economic Interests for Principal Investigators form indicating the negative disclosure. 
  • If the Principal Investigator, Principal Investigator’s spouse/registered domestic partner or dependent children indicate “Yes” for any of the questions in Section 3 (Filer Information), then the PI must submit the Statement of Economic Interests for Principal Investigators form and the Addendum for All Positive Disclosures to be reviewed by the Conflict of Interest Oversight Committee.

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