Instructions
For PHS and NSF
:
1. The Principal Investigator (PI) and each Investigator must sign the Disclosure as early as possible after the PI is informed that federal funding is
likely.
2.
Investigators having a significant related financial interest must also complete the Investigator’s Disclosure of Economic Interests Addendum.
Allow sufficient time for Sponsored Programs to complete a review, if necessary, and make a recommendation to the VP of Administration and
Finance
prior to award acceptance.
3. Submiss
ion of this form is also required on an annual basis for non-competing continuation awards, when a new Investigator is added to the
project, or when an Investigator’s financial interests increase, whichever comes first.
For PHS:
1. The de minimis disclosure threshold for a Significant Financial Interest on PHS funded projects is $5,000, which generally applies to payments for
services and equity interests. This includes any equity interest in non-publicly traded entities.
2. PIs are required to disclose the occurrence of any reimbursed travel or sponsored travel related to Institutional responsibilities (including purpose
of trip, sponsor/organizer, destination, and duration). Disclosure of travel reimbursements and Sponsored Travel does not include travel that is
reimbursed or sponsored by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an
academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
For other Sponsors
who have adopted the Federal disclosure requirements:
1.
The Principal Investigator (PI) and each Investigator must sign the Disclosure and forward it to Sponsored Programs with the complete proposal
package.
2.
Investigators having a significant related financial interest must also complete the Investigator’s Disclosure of Economic Interests Addendum.
Allow sufficient time for Sponsored
Programs to complete a review, if necessary, and make a recommendation to the VP of Administration and
Finance prior to award acceptance.
Definitions
Who Must Disclose? An individual involved in the design, conduct, or reporting of the results of work performed or to be performed under the
sponsored project. “Investigator” includes, but is not limited to the Principal Investigator, Co-Investigators, and any other individuals (including personnel
from other institutions) who are involved in accomplishing project objectives. It may include students, graduate and undergraduate, and other personnel
who may be listed as authors on project results, even if they are not paid from the project.
What is a “Significant Financial Interest”? Anything of monetary value, including, but not limited to:
1. Income exceeding $10,000 (or $5,000 for PHS projects) when aggregated for an Investigator and the Investigator’s spouse and dependent
children from a single Entity (Business, Public or Nonprofit) including salary, consultant payments, honoraria, royalty payments, dividend, loan, or
any other payments or consideration with value. Income from a Public or Nonprofit Entity for seminars, lectures, teaching engagements, or service
on advisory committees or review panels is exempt;
2. Equity in the form of stock, stock options, real estate, loan to, or any other investment or ownership interest exceeding $10,000 (or $5,000 for PHS
projects),
(current market value) or a 5% ownership interest, for any one enterprise when aggregated for an Investigator and the Investigator’s
spouse and dependent children;
3. A management position such as board member, director, officer, partner or trustee held by the Investigator, the Investigator’s spouse and/or
dependent children; or
4. Intellectual property interest held by the Investigator, or Investigator’s spouse or dependent children on a patent, patent application, or a copyright
of software assigned or to be assigned to a party other than The Trustees.
Financial Inter
est does not include (1) payments made by The Trustees (salary, royalties, honoraria, expense reimbursement or any other
remuneration) or (2) an investment by a mutual fund, pension fund or other investment fund over which the investigator or his/her immediate family
member does not exercise management of fund investment.
What is a “Related
Financial Interest”? The work to be performed under the sponsored project and results therefrom would reasonably appear to
affect the financial interest of the Investigator or the financial interest of the Entity in which the Investigator has an interest. The following are financial
interests “related” to a sponsored project:
1. 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;
2. 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;
3.
The Investigator has consulting income in his/her professional field that exceeds $10,000 from a single entity during the prior twelve months. The
Conflict of Interest Oversight Committee will provide an assessment for the Dean of Sponsored Programs as to whether any of that entity’s financial
interests, or the Investigator’s financial interests related to consulting for that entity, would reasonably appear to be affected by the federally-
sponsored research;
4. The Inves
tigator 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
5. The Investigator has a financial interest in an entity that is part of a consortium or that will otherwise participate in the sponsored project.
Review Process
Staff in Sponsored Progrmas will review the disclosure information to ensure completeness and consistency with prior disclosures. Information
provided in the Disclosures of those Investigators having a Related, Significant Financial Interest and additional appropriate documentation shall be
forwarded to the Cal Maritime Conflict of Interest Oversight Committee. The COIOC will consider whether the financial interests of the Investigator
or the Entity could be directly and significantly affected by the proposed sponsored project and whether the financial interest could affect the
design, conduct, or reporting of the project. A direct impact occurs when the project results would be directly relevant to the development,
manufacturing, or improvement of the products or services of the entity in which the employee has a financial interest, or when the entity is a
proposed subcontractor or participant in the project. A significant impact on the financial interest is one that will materially affect the value of the
organization, its earnings, or the sale of its products. The COIOC will review the information and make a recommendation to the VP of
Administration and Finance and Dean of Sponsored Programs, who are the responsible institutional officials.
Retention of Information: Three (3) years after termination of sponsored project or until resolution of any action by the sponsor, whichever is greater.
The Office of Record is the Cal Maritime Office of Human Resources.
