Non-Governmental Sponsors (State Policy)
- Requirements
- Exempt
- Forms
- For the State Process, Disclosable Interests Include
- COIOC Considerations for Review
- COIOC Considerations for Review Relating to Human Subjects
- Questions About the State Policy on Non-Governmental Sponsors?
Requirements
The State of California law and University policy require only the Principal Investigator disclose financial interests in the sponsor if the proposal is for a research project to be funded by a non-governmental source. State policy also requires research gift recipients to disclose financial interests when a gift is received from a non-governmental agency, such as a company or private foundation, which is earmarked by the donor for a specific principal investigator or a specific research project.
Exempt
All non-profit, tax-exempt educational institutions and many nonprofit foundations are exempted sponsors. Check the current listing of Non-Governmental Sponsors Exempt from the State Disclosure Process (700U) to determine when financial disclosures are not required.
Forms
The disclosure form, (Principal Investigator's Statement of Economic Interest, Form 700U), should accompany the proposal and the Administrative Approval Form to the Sponsored Projects Administration. Disclosures are filed by the PIs and Co-PIs, reflecting the cumulative interests for themselves and in certain situations their spouse and dependent children.
In the case of gifts, the disclosure form should accompany the Gift Acceptance Form sent to University Advancement.
For the State Process, Disclosable Interests Include
- Investments equal to or greater than $2000
- Position as director, officer, partner, trustee, employee or other management position
- Income within the prior 12 months or the promise of income equal to or greater than $500
- Gift from the sponsor/donor with the value equal to or greater than $50
- Ownership directly, indirectly or beneficially in any business entity or trust with a financial interest in sponsor greater than 10%.
- Loan from sponsor/donor with balance exceeding $500 in past 12 months.
- Travel and related expenses paid for by sponsor/donor
COIOC Considerations for Review
The COIOC will consider the research project according to traditionally held principles of ethical conduct and academic freedom. The COIOC will evaluate whether: there is sufficient separation of University and private interests, the proposed research is appropriate to the University, the teaching and research environment is open, freedom to publish and to disseminate research results is preserved, the University's rights are protected, the University's facilities and resources are used appropriately, and that the University receives proper compensation for their use.
Considerations for Review Relating to Human Subjects
The COIOC must consider the effect of the disclosed financial interests on the rights and welfare of the participants. The COIOC must consider whether the rights of the participants would be better protected by reduction or disclosure of a financial interest, separation of responsibilities for financial and research decisions, additional oversight, elimination of a financial interest, implementation of an independent data and monitoring committee, modification of roles in research staff, or any other mechanism which would mitigate effects of the financial interest."
Final COIOC approval is conditioned upon the Institutional Review Board's review of the COIOC findings and communication from the IRB that the COIOC has adequately considered the effect of the disclosed financial interests on the rights and welfare of the participants.
Questions About the State Policy on Non-Governmental Sponsors?
- Visit "UCI Guidance to PIs for Disclosure and Review of Financial Interest in Non-Governmental Sponsors of Research"
- UCI Policy
- UCI Procedures
