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).
|Transaction Type||Disclosure Guidance for UC Berkeley Investigators||Disclosure for Subrecipient Investigators||PI Approval|
|New Proposal||At the proposal stage, the UC Berkeley Principal Investigator (PI) is responsible for:
||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 all financial conflict of interest required by PHS have been disclosed to SPO and that they will abide by the PHS financial disclosure policy if the proposal is funded.|
|Pre-award: JIT Stage or when a Fund Advance is Requested||At the JIT stage or when requesting a fund advance prior to award stage, the UC Berkeley PI should:
|Post-Award||At the same time the RPPR is submitted the UC Berkeley PI should:
|NCE Request / Supplement Request that Extends the Project Period||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:
Unresolved COI issues can cause a delay in award set up/continuation. To prevent delays in award set up/continuation:
- 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.
- 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.