See Conflict of Interest Committee guidance on PHS Financial Disclosure for additional information on PHS financial conflict of interest (FCOI).

Transaction Type Disclosure for UC Berkeley Investigators? Disclosure for Investigators of Subagreements? PI Certification Required?
New Proposal Yes. The UC Berkeley Principal Investigator is responsible for identifying all UC Berkeley personnel that meet the PHS definition of an “investigator” and submitting to SPO a Form 1 for each UC Berkeley investigator named in the proposal. Yes. All non-FDP pilot subrecipients are responsible for completing the Subrecipient Commitment Form (4/2017 or later) and answering questions about the financial interests of all subrecipient investigators named in the Berkeley proposal. Yes. By approving the proposal in Phoebe, the Berkeley Principal Investigator and Co-Principal Investigator(s), are certifying that all financial disclosures required by PHS have been submitted to SPO and that they will abide by the PHS financial disclosure policy if the proposal is funded.

Note: The PI/Co-I should not approve the proposal without reading the text of this certification carefully.
JIT / Pre-Award Yes. The UC Berkeley PI should submit to SPO a Form 1 for any new UC Berkeley investigator added after proposal submission. No. Not applicable. No. Obtained at the proposal stage.
Fund Advance / Pre-Award Yes. Before requesting a fund advance, the UC Berkeley PI should submit to SPO a Form 1 for any new UC Berkeley investigator added to the project after JIT.

Note: Before a fund advance is issued, all positive FCOI disclosures must be resolved.
No. Not applicable. No. Obtained at the proposal stage.
Post-Award During the life of an award subject to PHS FCOI requirements:
  • The UC Berkeley PI should provide SPO with a Form 1 for all UC Berkeley investigators involved in the project on an annual basis. At UC Berkeley this occurs at the RPPR stage. (See below.)
  • The UC Berkeley PI should submit a Form 1 for any new UC Berkeley investigator added to an ongoing project before the investigator joins the project.
  • UC Berkeley investigators involved in an ongoing project are required to disclose to SPO any new Significant Financial Interests acquired or discovered within thirty (30) days of acquisition or discovery.
No. Not applicable. No. Not applicable.
Progress Report / Non-Competing Continuation Proposal (RPPR) Yes. On or before the due date of a Progress Report/Non-Competing Continuation Proposal (RPPR), the UC Berkeley PI should submit to SPO a Form 1 for all UC Berkeley investigators (as defined by regulations) participating in the project. This serves as the investigators’ annual disclosure. No. Not applicable. No. Obtained at the proposal stage.
Non-Competing Continuation Award Stage Yes. If the UC Berkeley PI failed to provide a Form 1 for each of the UC Berkeley investigators (as defined by regulations) participating in the project, the set-up of the continuation award will be delayed until the Berkeley PI submits the required annual disclosures to SPO.

Note: 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.
No. Not applicable. No. Obtained at the proposal stage.
NCE Request / Supplement Request that Extends the Project Period Yes. On or before the time a no-cost extension (NCE) is requested or a supplement that extends the period of performance of the award is requested, the UC Berkeley PI should submit to SPO a Form 1 for all UC Berkeley investigators that will be involved in the project during the new period of performance.

Note: Before the NCE/Supplement is set up, all positive FCOI disclosures must be resolved.
No. Not applicable. No. Obtained at the proposal stage.