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What SPO Requires: PHS FCOI Guide for Department Research Administrators and PIs

See Conflict of Interest Committee guidance on PHS Financial Disclosure for additional information on PHS FCOI.

Transaction Type Disclosure for UC Berkeley Investigators? Disclosure for Investigators of Subagreements without Policy? PI Certification Form/Email Required?
New Proposal or Competing Renewal Yes. The UC Berkeley PI is responsible for identifying all UC Berkeley investigators and submitting a Form 1 for each UC Berkeley investigator named in the application. Do not submit a Form 2 at this time. It will be requested, if needed, at the JIT/Pre-award stage. Yes. The UC Berkeley PI is responsible for identifying all sub investigators and submitting a Form 5 for each sub investigator named in the application. Yes, for proposals submitted with Phoebe, PI certification is included as part of the Phoebe approval. Any required disclosures must be included as attachments.

Yes, for non-Phoebe proposals, the UC Berkeley PI must submit a signed/dated PI Certification or email to SPO along with the required disclosures.
JIT/Pre-Award   Yes. The UC Berkeley PI should submit to SPO a Form 1 for each new UC Berkeley investigator involved in the project who has not previously submitted a Form 1. No. Not required. No. Not required.
Fund Advance Yes. The UC Berkeley PI should submit to SPO a Form 1 for each new UC Berkeley investigator involved in the project who has not previously submitted a Form 1 No. Not required. Yes, the UC Berkeley PI must submit a signed/dated PI Certification form or email to SPO along with required UC Berkeley investigator and sub investigator disclosures.
Award Stage Yes. The UC Berkeley PI should submit to SPO a Form 1 for each new UC Berkeley investigator who will be involved in the project who has not previously submitted a Form 1. Yes. When the UC Berkeley PI submits to SPO a request that a subaward be established, the PI is required to submit a Form 5 for each new sub investigator who will be involved in the project who has not previously submitted a Form 5. Yes, the UC Berkeley PI must submit a signed/dated PI Certification form or email to SPO along with required UC Berkeley investigator and sub investigator disclosures.
Non-Competing Continuation Application Stage Yes. Due to SPO on or before the application due date:
The UC Berkeley PI should submit a Form 1 for each UC Berkeley investigator who will continue to be involved in the next increment of the project.
Any UC Berkeley investigator that marks “Yes” on Form 1 also should submit a Form 2 to SPO.
Yes. Due to SPO on or before the application due date:
The UC Berkeley PI should submit a Form 5 for each sub investigator who will be involved in the next increment of the project.
Any sub investigator that marks “Yes” on Form 5 also should submit a Form 2 to SPO.
Yes, the UC Berkeley PI must submit a signed/dated PI Certification form or email to SPO along with the required UC Berkeley investigator and sub investigator disclosures.
Non-Competing Continuation Award Stage Yes. If the UC Berkeley PI failed to provide the required FCOI disclosure forms for UC Berkeley investigators at the application stage, this will be reported to the COI Coordinator.
SPO will not set up the new award increment without all required UC Berkeley investigator FCOI disclosure forms.
Departments should not expend the next increment’s funds until all required UC Berkeley investigator disclosures have been submitted and all positive disclosures have been resolved.
Yes. If the UC Berkeley PI failed to provide the required FCOI disclosure forms for sub investigators at the application stage, this will be reported to the COI Coordinator.
SPO will not set up the new award increment without all required sub investigator FCOI disclosure forms.
Departments should not expend the next increment’s funds until all required sub investigator disclosures have been submitted and all positive disclosures have been resolved.
If the UC Berkeley PI failed to provide a signed/dated PI Certification form or email at the application stage, this will be reported to the COI coordinator. SPO will not set up the new award increment without a signed/dated PI Certification Form or email to SPO.
NCE Request Supplement Request that Extends the Project Period Yes. The UC Berkeley PI should submit a Form 1 for each UC Berkeley investigator who will continue to be involved in the project.
Any UC Berkeley investigator that marks “Yes” on Form 1 also must submit a Form 2.
Yes. When the UC Berkeley PI requests a subaward be extended, the PI should also submit to SPO a Form 5 for each sub investigator who will continue to be involved in the project. Yes, the UC Berkeley PI must submit a signed/dated PI Certification form or email to SPO along with the required disclosures