Conflict of Interest

700-U Form

 

Form at a Glance:

 

Form Access:

 

 

 

 

 

 

 

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Please Note: The Addendum to Investigator's Statement of Economic Interests is required when a Principal Investigator (PI), Co-Principal Investigator, or Key Personnel have disclosed a financial interest on the 700-U form or the 9510 form.

 

  • 9510 form - Disclosure of Financial Interests Related to Federal and Other Sponsored Projects Adopting the Federal Requirements.

Please Note: For UC Discovery Grant Program, the Principal Investigators (PI) and Co-Principal Investigators (Co-PI) must submit both the 700-U form and the 9510 form. Other Investigators on UC Discovery Grants must submit the 9510 form only, and not the 700-U.

What is the 700-U form?

 

 

 

 

 

 

 

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The 700-U form is the...

  • Statement of Economic Interests for Principal Investigators.

 

Changes to Form 700-U: In July 2005, the State of California's Fair Political Practices Commission issued a revised Statement of Economics Interests (700-U) form. The revised form eliminates the need for a completion statement and adds a separate entry line for renewal funding. In addition, the 700-U Instructions now include a Privacy Information Notice with reference to the requirements of the Political Reform Act.

 

Please Note: The State of California 700-U form, differs from the Federal 9510 form, which require, in addition to the Principal Investigator and Co-Principal Investigator, Other Investigators and Key and Other Personnel to disclose economic interests related to Federally-Sponsored projects.  

When is the 700-U form required?

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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The 700-U form is required for...

  • Non-Federal Sponsored Projects, which include;

  • Gifts

  • Private Grants

  • For Profit Contracts, which include;

    • Research Agreements

    • UC Discovery Grant Program, which includes;

      • bio - Biotechnology

      • com - Communications and Networking

      • dig - Digital Media

      • ele - Electronics Manufacturing and New Materials

      • itls - Information Technology for Life Sciences

      • MICRO - Microelectronics

      • Please Note: The 9510 form is also required when submitting a proposal to any UC Discovery Grant Program listed above.

    • Material Transfer Agreements (MTA); please fill out the appropriate Material Transfer Process form first, before proceeding with the 700-U, as the 700-U may not be required.

    • Clinical Trial Agreements

    • Lab Service Agreements

 

  • For information regarding Sponsors that may be exempt from 700-U requirement, click here.

When is the 700-U not required?

 

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The 700-U form is not required for...

  • Researchers other than the PI or Co-PI

  • Non Profit entities on the State Exempt List, which includes all Non Profit tax exempt educational institutions.

Why is the 700-U form required?

 

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The 700-U form is required by...

  • The State of California Fair Political Practices Commission for disclosure of any financial interest in non-federal sponsors of research and gifts administered by the University.

Who is required to submit a 700-U form?

 

 

 

 

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Individuals required to submit the 700-U form include...

  • Principal Investigators (PI) - A UCSD employee, normally an academic appointee, who has primary responsibility for the scientific and technical conduct, reporting, fiscal, and programmatic administration of a sponsored project.

  • Co-Principal Investigators (Co-PI) - One of two or more UCSD Investigators who share responsibility for the scientific and technical conduct, reporting, fiscal, and programmatic administration of a sponsored project.

 

For UC Discovery Grant Program...

  • Principal Investigators (PI)

  • Co-Principal Investigators (Co-PI)

    ...must submit both the 700-U form and the 9510 form.

  • Key Personnel must submit the 9510 form only, and not the 700-U.

What financial interests need to be disclosed on the 700-U form?

 

 

 

 

 

 

 

 

 

 

 

 

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The term financial interest is applicable for an investigator, the investigator’s spouse, the investigator's registered domestic partner, and/or dependent children and must include the following disclosures...

  • Holding a position as director, officer, partner, trustee, employee of or any other position of management in the sponsor or donor.

  • Income received from the sponsor or donor of $500 or more.  Reportable income includes salary, consulting payments, honoraria, royalty payments, dividends, or any other payments or consideration with value, including payments made to the University of California Health Sciences Compensation Plans.

  • A direct or indirect equity interest in the sponsor or donor of  $2,000 or more.  Reportable investments include, stocks, bonds, warrants, and options, including those held in margin or brokerage accounts.

  • Receipt or promise of personal gifts from the sponsor aggregating $50 or more in value.  A gift is reportable if its fair market value is $50 or more. In addition, multiple gifts totaling $50 or more received from a single source must be reported.

  • A loan received or outstanding totaling $500 or more from a single lender. Reportable loans include community property interest in loans received by a spouse.

  • Payments for transportation outside of California are reportable and any travel payments received from the sponsor or donor.  Reportable travel payments include advances and reimbursements for travel and related expenses, including lodging and meals.

What financial interests do not need to be disclosed on the 700-U form?

 

 

 

 

 

 

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Financial interests that do not need to be disclosed include..

  • Travel payments received from any state, local, or federal government agency for which you provided services equal or greater in value than the payments received.

  • Travel payments received from your employer in the normal course of your employment.

  • Payments or reimbursements for transportation within California in connection with an event at which you gave a speech, participated in a panel or seminar, or performed a similar service.

  • Food, beverages, and necessary accommodations received directly in connection with an event held inside or outside California at which you gave a speech, participated in a panel, or provided a similar service.

  • A travel payment which was received from a Non Profit entity exempt from taxation under IRS Code section 501(c)(3) for which you provided equal or greater consideration. Check the box, on the 700-U form Section 3, part F, to indicate if the payment was a gift or income, report the amount, and disclose the date(s) if applicable.

When must I submit the 700-U form?

 

 

 

 

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The 700-U form is submitted...

  • At the time of submission for any contract or grant proposal or proposal for gift funding.

  • Prior to final acceptance of a contract, grant, or gift.

  • When funding is renewed.

  • Any time a change of investigator is made, which could include; a change of PI or the addition of a Co-PI to the project.

  • Whenever an investigator has a change in reportable financial interests during the term of an award for which disclosure is required.

  • Within 90 days after completion, in the case of a contract or grant, or after funds have been expended, as in the case of a gift.

Where do I submit the 700-U form?

 

 

 

 

 

 

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All required disclosure forms must be completed and submitted with the funding proposal to the appropriate reviewing office...

  • OCGA - Office of Contract and Grant Administration, for Research Agreements and Private Grants, such as UC Discovery Grant Program and Material Transfer Agreements for General Campus and Health Sciences.

  • SIO - Scripps Institution of Oceanography, Contract & Grant Office for research agreements at SIO.

  • Health Sciences Office of Clinical Trial Administrative Services for clinical trial agreements.

  • Health Sciences Legal Liaison for lab service agreements.

  • Office of Gift Administration for unrestricted gifts.

 

Please Note: An original signature is always preferred, however faxed signatures will be accepted.

What happens after the 700-U form is submitted?

 

 

 

 

 

 

 

 

 

 

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After the 700-U form is submitted...

  • The form is sent to the appropriate proposal reviewing office.

  • The proposal reviewing office sends the form to the Conflict of Interest (COI) Office.

  • If no financial interest exists, then 700-U form is approved. This is referred to as a Negative Disclosure. The COI Office informs the proposal reviewing office to release funds upon receipt of the award.

  • If a financial interest exists, this is referred to as a Positive Disclosure:

  • The COI Office informs the proposal reviewing office to hold funds until the disclosure is reviewed by the Independent Review Committee (IRC) on Conflict of Interest.

  • The COI Office requests the PI and Co-PI complete the Addendum to Investigator's Statement of Economic Interests form.

  • Additional information may be required from the PI and/or Co-PI to be sent to the COI Office. For example; a copy of the Consulting Agreement must be provided.

 

Keep in mind that once the disclosure of financial interests forms have been submitted, they can be made available, upon request, to the public, under the California Public Records Act.

What is the Independent Review Committee's (IRC) review process?

 

 

 

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The IRC review process includes the following actions...

  • Reviews disclosure forms on a monthly basis.

  • May request PI/Co-PI to make changes in their financial relationship with company or donor. For further detail information regarding the IRC, click here.

  • Makes written recommendations to the Chancellor to manage, eliminate and/or reduce conflict of interest.

  • Chancellor executes a letter after this review and concurrence with IRC’s recommendations.

  • The COI Office sends copies of Chancellor’s concurrence letter to PI, Department Chair and others, as appropriate.

  • COI Office informs the reviewing office that the award may be accepted, as appropriate.

Is there an appeal process to the IRC's recommendations?

 

 

 

 

 

 

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If the Investigator does not agree with the IRC’s recommendations…

  • The Investigator will contact the IRC.

  • The investigator will also be asked to discuss this matter with their Dean and/or Vice Chancellor to implement the IRC’s requests recommendations or to suggest an acceptable alternative to manage the conflict of interest.

  • The IRC will meet with the Dean and/or Vice Chancellor to discuss the matter.

  • If all attempts to mediate the conflict of interest situation have not been successful, and the PI or Researcher is still not in agreement with the recommendations made by the IRC, the IRC will then recommend that funding for the project not be accepted and forward this recommendation to the Chancellor for concurrence.

  • If the PI does not concur with the IRC's recommended management strategies even after this process, the PI can appeal the decision to the Chancellor for review.

What happens if I am required to submit the 700-U form and do not?

 

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The University states...

  • Failure to file the required Statement of Economic Interests or failure to report a financial interest may subject the individual to civil liability, including fines, as well as University discipline (Government Code sections 81000-91014).

 

Contact Information:

Valerie McFarland

Director

858-534-6465

vmcfarland@ucsd.edu

Amber O'Banion

Senior Administrative Analyst

858-534-3695

aobanion@ucsd.edu

Mya Hines

Administrative Assistant

858-822-1636

mdhines@ucsd.edu

 

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