FINANCIAL INTEREST DISCLOSURE REQUIREMENTS

 

 

STATE

FEDERAL

Reporting Triggers

▪     Research contract/grant from a non-governmental entity (including the industry sponsor match for UC Discovery Grants)      

▪     Gift (earmarked specifically for research or for a specific PI)

▪     Material Transfer Agreement (when the MTA constitutes a request to support research)

▪     Proposed License Agreement (if lead inventor has a financial interest in the licensee)

Note:  Some non-governmental sponsors are exempted from the disclosure requirements.  See exempt list.

▪    Federal research contract/grant

▪     Non-governmental entity which flows down federal funds (excluding SBIR/STTR Phase I awards)

▪    Grant from the American Cancer Society or American Heart Association

▪    UC Discovery Grants

▪     UC Special Research Programs (HIV/AIDS, breast cancer, and tobacco-related disease)

▪    CIRM

Who Must Disclose

▪     UCLA Principal Investigator(s)

▪     Other Investigators (UCLA employee who shares responsibility for design, conduct, or reporting of the results of a sponsored project)

▪     Lead UCLA Inventor

▪     UCLA Principal Investigator(s)

▪     Other Investigators (UCLA employee who shares responsibility for design, conduct, or reporting of the results of a sponsored project)

What to Disclose

For the PI:  A financial interest in the sponsor of the research, or candidate licensee including:

▪     Income ³ $500

▪     Investments ³ $2,000

▪     Director, Officer, Employee, Partner, Trustee, Consultant or Management position (paid or unpaid)

▪     Loan balances ³ $500

▪     Gifts valued at ³ $50

▪     Travel

For Other Investigators:  A significant financial interest in the sponsor of the research including:

▪     Income ³ $10,000

▪     Equity ³ $10,000 or 5%

▪     Director, Officer, Employee, Partner, Trustee, Consultant or Management position (paid or unpaid)

▪     Intellectual property

Note:  Financial interests must be reported for the discloser and his/her spouse or registered domestic partner, and dependent children.

A significant financial interest related to the research project, including:

▪     Income ³ $10,000

▪     Equity ³ $10,000 or 5%

▪     Director, Officer, Employee, Partner, Trustee, Consultant or Management position (paid or unpaid)

▪     Intellectual property

 

Note:  Financial interest must be reported for the discloser and his/her spouse or registered domestic partner, and dependent children. 

When to Disclose

▪     With the initial proposal

▪     With additional funding

Note:  All positive disclosures must be reviewed and approved prior to acceptance of the award or additional funding.

▪     Upon identification of one or more candidate licensee companies (possibly prior to the signing of any secrecy agreement)

▪     With all competing proposals (new & renewal)

▪     With non-competing continuations (PHS only)

▪     With requests for no-cost time extensions

▪     With supplemental funding

▪     When new personnel are added

▪     Whenever there is a change in an Investigator’s interest

Note:  All positive disclosures must be reviewed and approved prior to acceptance of the award or additional funding, or prior to new personnel joining the project.

Disclosure Forms

Principal Investigator: 

▪     State Form 700-U

▪     UCLA Form 700-U Addendum

▪     Supplement* (if positive)

*For Clinical Trials, complete Industry Clinical Trial Specific Disclosure Supplement online smart form

Other Investigators:

▪     UCLA Form 700-U Addendum

▪     Supplement* (if positive)

*For Clinical Trials, complete Industry Clinical Trial Specific Disclosure Supplement online smart form

Lead Inventor

▪     UCLA TT-100

All Principal Investigators and Other Investigators:

▪     UCLA Form 740

▪     UCLA Form 740 Supplement (if positive)

 

Definitions:

 

Key Position/Management Position includes any position of management, whether paid or unpaid, including director, officer, partner, trustee, consultant, employee, or board member.

 

Income includes but is not limited to salaries, wages, advances, dividends, interest, rent, proceeds from sale, gifts (incl. food & beverage), loan forgiveness, expense reimbursement, per diem, contributions to insurance/pension programs, outstanding loans.

 

Investments include any direct, indirect or beneficial financial interest in a business, stocks, bonds, warrants, options.

 

Gifts are anything of value for which equal or greater consideration have not been provided.  Gifts commonly include:  tickets/passes to sporting or entertainment events or amusement parks; parking passes; food, beverages and accommodations including that provided in direct connection with attendance at a convention, conference, meeting, social event, meal, or like gathering, where a speech, participation in a panel or seminar, or similar service was not provided; rebates/discounts not made in the regular course of business to members of the public; wedding gifts; honoraria (honoraria may be reported as income if the services provided were of equal or greater value than the payment received); transportation and lodging; and forgiveness of a loan received by the discloser. 

 

Travel includes advances and reimbursements for travel and related expenses, including lodging and meals.  Travel payments are considered gifts if no services equal to or greater in value than the payments received are provided.  Gifts of travel ³$50 must be disclosed (a description and dates must be provided).  Travel payments are considered income if services equal to or greater in value than the payments received are provided.  Travel income ³$500 must be disclosed (a description of the services must be provided; dates are not required to be disclosed for travel income).  Disclosure is not required for:  payments for transportation within California in connection with an event in which a speech, participation in a panel or seminar, or similar service was provided; food, beverages and necessary accommodations received directly in connection w/an event held inside or outside California at which a speech, participation in a panel, or similar service was provided (payments for transportation outside California are reportable); payments from 501(c)(3) nonprofit entities for which services of equal or greater consideration are provided. 

 

For further information on financial conflicts of interest in research, see UCLA Policy 925 and UCLA Procedures 925.1, 925.2, and 925.3.