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 financial conflict of interest (FCOI).

PHS FCOI Guidance

Transaction Type Disclosure Guidance for UC Berkeley Investigators Disclosure for Subrecipient Investigators PI Approval
New Proposal PI Tasks:

  1. Identify all UC Berkeley personnel involved in the project that meet the PHS definition of an “investigator.” (See Note #1 below.)
  2. Complete the PHS Financial Interest screening questions in Phoebe Proposal on behalf of all UC Berkeley investigators involved in the project.
  3. List the names of any investigators that prompted the PI to answer “Yes” to any of the screening questions.
Note #1: “Investigator” is defined as the Principal Investigator (PI) and any other person/s (regardless of title or position) that the PI identifies as independently responsible for the design, conduct, or reporting of the research.

Note #2: If it is not possible for the UC Berkeley PI to complete the screening questions in Phoebe Proposal, the UC Berkeley PI should answer the screening questions on the PHS Financial Interest Screening Questions Form on behalf of all identified UC Berkeley investigators involved in the project and email this form to the SPO CGO.		 An authorized official of each FDP subrecipient is responsible for completing the most current Subrecipient Commitment Form and answering questions about the financial interests on behalf of all subrecipient investigators named in the Berkeley proposal. By approving the proposal in Phoebe, the Berkeley Principal Investigator and Co-Principal Investigator(s), are certifying that the answers to the screening questions in Phoebe or on the PHS Financial Interest Form: Screening Questions are true and correct and that the PI will abide by the PHS financial disclosure policy if the proposal is funded.
Pre-award: JIT Stage or when a Fund Advance is Requested PI Tasks:

The UC Berkeley PI should update the PHS Financial Interest Screening Questions Form and submit the form to SPO if:
  • Any new UC Berkeley investigators were added to the project since the proposal was submitted, and/or
  • Any existing investigators have acquired a new reportable financial interest since the proposal was submitted.
Note: Direct any investigator that prompted the PI to provide a “Yes” answer to the any of the screening questions to complete and submit a PHS Financial Disclosure Form to the COI Office at coi-team@berkeley.edu.
Award Stage (if no JIT) PI Tasks:

The UC Berkeley PI should update the PHS Financial Interest Screening Questions Form and submit the form to SPO if:
  • Any new UC Berkeley investigators were added to the project since the proposal was submitted, and/or
  • Any existing investigators have acquired a new reportable financial interest since the proposal was submitted.
Note: Direct any investigator that prompted the PI to provide a “Yes” answer to the any of the screening questions to complete and submit a PHS Financial Disclosure Form to the COI Office at coi-team@berkeley.edu.
Non-Competing Continuation (RPPRs) PI Tasks:

  1. Update the PHS Financial Interest Screening Questions Form on behalf of all UC Berkeley investigators involved in the project at the time the RPPR is submitted. (This will serve as each investigator’s required annual disclosure.)
  2. Send the updated form to the SPO CGO.
  3. Direct any investigator that prompted the PI to provide a “Yes” answer to the any of the screening questions to complete and submit a PHS Financial Disclosure Form to the SPO CGO.
Requests that Extends the Budget Period (e.g. NCE) PI Tasks:

  1. Submit an updated PHS Financial Interest Screening Questions Form on behalf of all UC Berkeley investigators that will be involved in the project during the new budget period.
  2. Direct any investigator that prompted the PI to provide a “Yes” answer to the screening questions to complete and submit a PHS Financial Disclosure Form to the SPO CGO.
During the Life of the Award:
When adding a new investigator or when an existing investigator acquires a new reportable financial interest		 Within 30 days, the PI should:

  1. Update the PHS Financial Interest Screening Questions Form and submit the form to the SPO CGO.
  2. Direct any investigator that prompted the PI to provide a “Yes” answer to the any of the screening questions to complete and submit a PHS Financial Disclosure Form to the SPO CGO.

Unresolved COI issues can cause a delay in award set up/continuation. To prevent delays in award set up/continuation:

  1. The UC Berkeley PI should answer the screening questions in Phoebe and/or on the PHS Financial Interest Screening Questions Form at the different stages described above.
  2. Investigators that prompt the PI to provide a “Yes” answer to the any of the screening questions should complete and email a PHS Financial Disclosure Form to the SPO CGO.

Note: Departments should not expend the next increment’s funds to be processed until all required UC Berkeley investigator disclosures have been submitted and all positive disclosures have been resolved.

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