Overview of Disclosure Obligations

Researchers are required to disclose their activities, affiliations, and financial interests ("activity") with outside entities and organizations for different compliance reasons. Often this information overlaps so this page highlights what records you should be maintaining and how that information should be disclosed based on each requirement.

Information Required for Different Types of Disclosures

Based on the nature of the activity with an outside entity, the information you need to maintain in your records will vary.  For each, consider the following characteristics to help determine which information is necessary. Please note in some cases, more than one category will apply so you will need to maintain all the applicable necessary information.

    Federal Biographical Sketch

    Required in federal and federal flow-through proposal applications generally for senior/key personnel or covered individuals

    Information required
    • Entity Name
    • Location of Entity
    • Position: Employee, Consultant, Executive or Managerial Position, Board of Directors, Scientific Advisor, C-Level executive position or any title
    • Date(s)/Year(s) of Activity
    Notes

    Disclose in “Positions, Scientific Appointments, and Honors,” “Appointments and Positions,” and similar sections in the Federal Biographical Sketch.

    Contracts and Grants Officer

    Federal Other/Current & Pending Support

    Required in federal and federal flow-through proposal applications generally for senior/key personnel or covered individuals sometimes with the proposal submission or at Just-in-Time

    Information required

    Disclose all research support including in-kind contributions that require a commitment of the individual's time and support the individual's research and development efforts

    • Entity Name
    • Location of Entity
    • Date(s)/Year(s) of Activity
    • Description of Activity
    • Research Support (including in-kind): Visiting student/scholar, equipment, resources, lab space, etc.
    • Research Funding or Estimated Value of Research Support
    • Project Title
    • Effort
    Notes

    Other/Current & Pending Support information for research proposals and awards processed through UCI can be found through the Current & Pending Support Report.

    An in-kind contribution is a non-cash contribution provided by an external entity that directly supports the individuals' research and development efforts. An in-kind contribution may include but is not limited to: real property; office/laboratory space; equipment; data or data sets; supplies; other expendable property; goods and services; employee or student supported by an outside source (non-UCI). 

    Contracts and Grants Officer

    Federal Research Performance Progress Report (RPPR)

    Changes in other/current & pending support, new senior/key personnel or participants, and other collaborators or contacts must be updated in federal annual progress reports generally for senior/key personnel or covered individuals

    Information required

    Changes in other/current & pending support for participants or senior/key personnel

    Disclose when there has been a change in the active other support of the participants or senior/key personnel since the last reporting period. Describe active other support and include what the change has been.

    • Entity Name
    • Location of Entity
    • Date(s)/Year(s) of Activity
    • Description of Activity
    • Research Support (including in-kind): Visiting student/scholar, equipment, resources, lab space, etc.
    • Research Funding or Estimated Value of Research Support
    • Project Title
    • Effort

    New senior/key personnel

    Upload biosketches and other/current & pending support for all new senior/key personnel

    Notes

    Other Collaborators

    Also may need to update the list of collaborators involved in the project in the RPPR Participants and Other Collaborating Organizations section

    Resources:

    Contracts and Grants Officer

    Public Health Service/Department of Energy Conflict of Interest

    Required for all Investigators (individuals responsible for the design, conduct or reporting of the project) on PHS/DOE compliant proposals and awards

    Information required
    • Entity Name
    • Status of Entity: Publicly Traded, Privately Held
    • Date Received Financial Interest
    • Financial Interest Type
      • Income
      • Equity (stock, stock options, ownership interests)
      • Non-UC Regents owned intellectual property rights
      • Amount
    • Travel Reimbursements
      • Location
      • Date(s)
      • Purpose
    • Description of Activity
    Notes

    Disclose all significant financial interests related to the individual’s institutional responsibilities (UCI academic research and educational interests). 

    If publicly traded entity, disclose when total value of compensation and equity interest > $5,000

    If privately held entity, disclose when total value of compensation > $5,000 or any equity interest

    Sponsored or reimbursed travel disclosures should be disclosed in a separate form, PHS/DOE Travel Log.

    Conflict of Interest Team

    National Science Foundation/National Aeronautics and Space Administration Conflict of Interest

    Required for all Investigators (individuals responsible for the design, conduct or reporting of the project) on NSF/NASA compliant proposals and awards

    Information required
    • Entity Name
    • Date Received Financial Interest
    • Financial Interest Type
      • Income
      • Equity (stock, stock options, ownership interests)
      • Non-UC Regents owned intellectual property
      • Amounts
    • Description of Activity
    Notes

    Disclose all significant financial interests related to the NSF/NASA Compliant proposal or award.

    Salary, honoraria, royalties, venture or other capital financing, or other payments > $10,000 (excluding income from seminars, lectures, teaching engagements, or service on advisory committees or review panels for public or nonprofit entities)

    Equity interest > $10,000 or 5% ownership interest

    Any non-UC Regents owned intellectual property interest in a patent, patent application, or copyright of a software

    Conflict of Interest Team

    UC OATS (Conflict of Commitment)

    In accordance with APM 025 and APM 671 policies, faculty are required to report involvement in outside professional activities, including requesting prior approval before engaging in Category I activities, and reporting time and compensation engaging in the activity.

    Information required
    • Entity Name
    • (APM-671 Only) Income Amount
    • Date of Activity
    • Position
      • For a full list of outside professional activities that require disclosure, please visit APP 1-15.
      • To request prior approval before engaging in an outside professional activity and report any activities, please visit the UC OATS website.
    • Hours/Days Spent
    • Description of Activity
    Notes

    Faculty subject to APM 025 and APM 671
    APM 025 and APM 671 applies to faculty holding appointments in one of the following title series at 50 percent or more:

      1. Professor, including Acting titles
      2. Professor in Residence
      3. Adjunct Professor
      4. Professor of Clinical (e.g., Medicine)*
      5. Health Sciences Clinical Professor*
      6. Professor of Teaching

    Faculty holding titles in these series are subject to APM 025 if not participating in the Health Sciences Compensation Plan. Faculty participating in the Health Sciences Compensation Plan are subject to APM 671 and are not subject to APM 025.

    Recalled Faculty

      1. Faculty who have retired and recalled to active service for appointments at or less than 43 percent time are not subject to APM 025.
      2. Health Sciences Compensation Plan Faculty:  Faculty who have retired and recalled to active service for appointments at or less than 43 percent time are subject to the provision of APM 671.

    Policy Questions

    Technical UC OATS Questions

    State Conflict of Interest for Non-governmental Sponsors

    Only required from Principal Investigators and Co-Principal Investigators on non-governmental sponsored research awards and gifts.

    Information required
    • Entity Name
    • Financial Interest Type
      • Income
      • Equity (stock, stock options, ownership interests)
      • Loans
      • Gifts
      • Amounts
    • Date Received Financial Interest
    • Position: Employee, Consultant, Executive or Managerial Position, Board of Directors, C-Level executive position
    • Travel Reimbursements
      • Location
      • Dates
      • Estimated Value
      • Purpose
    Notes

    Only disclose financial interests in the non-governmental sponsor or prime sponsor.

    Conflict of Interest Team

    Human Subjects Research Conflict of Interest

    All research personnel listed on an IRB protocol must disclose all disclosable financial interests related to the IRB protocol.

    Information required
    • Entity Name
    • Status of Entity: Publicly Traded, Privately Held
    • Financial Interest Type
      • Income
      • Equity (non-UC Regents owned)
      • Non-UC Regents owned intellectual property interest
      • Amounts
    • Date Received Financial Interest
    • Position: Employee, Consultant, Executive or Managerial Position, Board of Directors, C-Level executive position
    Notes

    Disclose if your financial interest meets one or more the following AND relates to the IRB protocol:

    • Income > $10,000
    • Publicly traded company: equity interest > $10,000 or 5%
    • Any equity interest in a privately held company, regardless of value
    • Intellectual Property interest in a patent, patent application, or copyright of a software

    Related: Related financial interests occur when the researcher, their spouse/registered domestic partner or dependent children have a disclosable financial interest that would reasonably appear to be affected by the research or when the entity in which the financial interests are held would reasonably appear to be affected by the research. To assist in the disclosure process, the following examples are provided:

    • The project results could be relevant to the development, manufacturing, or improvement of products or services of the entity in which the researcher has a financial interest;
    • The researcher has a financial interest in an entity that might manufacture, commercialize or license a drug, device, procedure or any other product used in the project or that will predictably result from the project;
    • The researcher received compensation from activities in his/her professional field during the prior twelve months, where the financial interest of the entity or the investigator would reasonably appear to be affected by the project;
    • The research involves a product, services, method, etc. that competes or is an alternative to the entity's product, services, method, etc.;
    • The researcher has a financial interest in an entity and the 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 researcher has a financial interest in an entity that is part of a consortium or that will otherwise participate in the project.

    Conflict of Interest Team