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:
  1. Identifying all UC Berkeley personnel involved in the project that meet the PHS definition of an “investigator.” “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.
  2. Completing the PHS Financial Interest screening questions in Phoebe Proposal on behalf of all UC Berkeley investigators involved in the project.
  3. Listing the names of any investigators that prompted the PI to answer “Yes” to any of the screening questions in Phoebe or on the PHS Financial Interest Screening Questions Form.
Note: 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 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:
  1. Complete the PHS Financial Interest Screening Questions Form on behalf of any new UC Berkeley investigators added to the project since the proposal was submitted.
  2. Ask all of the investigators included in the proposal that prompted the PI to provide a “Yes” answer to the screening questions to complete and email a PHS Financial Disclosure Form to the SPO CGO.
  3. Ask all of the newly added investigators that prompted the PI to provide a “Yes” answer to the screening questions to complete and email a PHS Financial Disclosure Form to the SPO CGO.
   
Post-Award At the same time the RPPR is submitted the UC Berkeley PI should:
  1. Answer the screening questions on the PHS Financial Interest Screening Questions Form on behalf of all UC Berkeley investigators involved in the project at that time. (This will serve as each investigator’s required annual disclosure.) This form should be sent 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 email a PHS Financial Disclosure Form to the SPO CGO.
Before an investigator joins the PI’s project, the PI should:
  1. Answer the screening questions on the PHS Financial Interest Screening Questions Form on behalf of any new UC Berkeley investigators. This form should be submitted 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 email a PHS Financial Disclosure Form to the SPO CGO.
During the life of the project if a PI discovers that an investigator involved in the project has acquired a new Significant Financial Interest the PI should:
  1. Tell the investigator to complete and email a PHS Financial Disclosure Form to the SPO CGO.
  2. This should occur within thirty (30) days of acquisition or discovery.
   
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:
  1. Submit a PHS Financial Interest Screening Questions Form on behalf of all UC Berkeley investigators that will be involved in the project during the new period of performance.
  2. Direct any investigator that prompted the PI to provide a “Yes” answer to the screening questions to complete and email 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.