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Disclosure of Financial Interests and Management of Conflicts of Interest for Public Health Service Research Awarded to LBNL


  • Conflict of Interest Coordinator: Molly Stoufer, Research and Institutional Integrity Office, 510-486-5820 [email protected]

Mandatory Conflict of Interest Rules for all PHS/NIH Funded Researchers

Berkeley Lab has updated Conflict of Interest in Research policy to comply with revised Public Health Service regulations described below. The new regulations apply only to PHS-funded grants and cooperative agreements, including noncompeting continuing awards. They do not apply to no cost extensions.

The policy differs from prior rules for disclosure and review of personal financial interests related to PHS funded research in three key areas:

  • Lower thresholds for disclosure
  • Expanded scope of what must be disclosed
  • Required COI training
The policy is available in the RPM at: 

Summary and FAQs

The U.S. Department of Health and Human Services and the Public Health Service (PHS) have issued new financial conflict of interest (FCOI) disclosure regulations. These FCOI regulations establish standards and thresholds for financial disclosures that must be followed by institutions that apply for or receive research support from PHS agencies, including the National Institutes of Health (NIH). The rules also apply to a handful of non-federal sponsors. Please consult the list of Federal and non-Federal sponsors that have adopted the PHS regulations.

Mandatory financial disclosures: The FCOI regulations differ in several significant ways from the prior rules, including reduced disclosure thresholds and more expanded review and reporting obligations:

Who must disclose?
Any personnel on a PHS-funded project who are responsible for the design, conduct or reporting of the research.  This would include senior and key personnel and all others who contribute to the scientific development or execution and reporting of a project in a substantive, measurable way whether or not they request or receive salary or compensation.  The requirement for disclosure extends to income and equity held by the spouse, registered domestic partner and dependent child(ren) of such personnel.

When must disclosure be made?
Personnel must disclose any Significant Financial Interests related to their Institutional Responsibilities at the time a proposal is submitted for PHS funding, at least annually throughout the period of any resulting award and within thirty (30) days of acquiring or discovering any new Significant Financial Interest.

What must be disclosed?

  • Publicly traded equity owned or acquired in the previous 12 months in any Publicly Traded Entity, the value of which exceeds $5,000.  Mutual funds or retirement funds over which you do not control investment decisions are excluded.
  • Any equity interest owned or acquired in the previous 12 months in any non-Publicly Traded Entity, which exceeds $5,000.  This includes any stock, stock option or other ownership interest.
  • Any income or other payment for services received within the previous 12 months from any entity, which exceeded $5,000.  Payments from the Regents, income from seminars, lectures or teaching engagements sponsored by a federal, state or local government, a U.S. institution of higher education, or a research institute, academic medical center or hospital affiliated with a U.S. institution of higher education are excluded.
  • Any payments received within the past 12 months for any intellectual property rights and interests (e.g., patents, copyrights, assigned or licensed to a party other than the Regents), which exceed $5,000.
  • Any travel reimbursement or payment totaling over $5000 per entity, within the past 12 months.  Payments from federal, state or local governments, U.S. institutions of higher education, or a research institute, academic medical center or hospital affiliated with U.S. institution of higher education are excluded.

What else is required?
Mandatory Training: The FCOI regulations also include new requirements for mandatory and ongoing education and training. UC-required Conflict of Interest for Researchers training, delivered through the Lab’s JHA (Job Hazards Analysis) system, satisfies the mandatory training under the new FCOI rules. All PHS investigators, as defined by the rule, must complete this training prior to beginning work on a PHS-funded project with a Notice of Award issue date after August 24th. You may access the training through your JHA training profile ( or directly at:

Regulations:  The regulations and updated FAQs prepared by the NIH can be accessed at the NIH Financial Conflict of Interest webpage.

Contact: For any other questions or concerns, please contact us at [email protected]

UC Policy on Disclosure of Financial Interests & Management of Conflicts of Interest, Public Health Service Research Awards
NIH Financial Conflict of Interest webpage
FAQs on the New PHS/NIH Financial Conflicts of Interest Regulations

COI Forms for LBNL PHS Proposals

Please direct questions to [email protected].


Last updated 08/26/2014
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