Department of Energy (DOE)

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For Research Funded by Department of Energy (DOE)
 

DOE Financial Disclosure

The Department of Energy recently issued a new, interim conflict of interest rule that requires additional compliance components from investigators with current and upcoming DOE funding, either directly or by subaward. The new policy closely mirrors COI requirements that have been in place for the last decade for recipients of Public Health Service funding. Comprehensive information about the requirements of this policy are below.
 

DOE Reporting Triggers
  • DOE research contract/grant
  • Non-governmental entity which flows down DOE funds
  • Research Funding from organizations that follow DOE disclosure requirements.
    Note: Exclude Phase 1 SBIR or STTR and Office of Indian Energy grants
     
Who Discloses

Investigator: Any individual responsible for the purpose, design, conduct, or reporting of research performed or to be performed with DOE funding or a subaward from a pass-through entity to carry out part of a DOE award (subrecipient), regardless of whether the Investigator receives compensation from the DOE funding.  Investigators may include collaborators, consultants, non-UCR personnel, postdoctoral fellows and students depending on their responsibilities for the funded research. For example, reporting includes authorship on publications resulting from the research; thus, graduate and undergraduate students may be required to disclose as Investigators.   

  • Note: DOE program offices have the discretion to expand this definition to include also any person who participates in the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. Such expansion will be specified in the applicable funding opportunity announcement and/or terms and conditions of the financial assistance award.
     
When to Disclose
  • With the initial and renewal proposals
  • With supplemental funding proposal
  • With non‐competing continuation
  • With no cost time extension
  • When a new Investigator(s) is added
  • At least annually for duration of project
  • With any new significant financial interest (New significant financial interests must be reported within 30 days of acquiring or discovering the new SFI.)
     
What to Disclose

Investigators must disclose the following financial interests in themselves, their spouse/registered domestic partner, and dependent child(ren).
A significant financial interest related to the investigator’s institutional responsibilities including:

  • If publicly traded entity, total value of remuneration and equity interest (including stock, stock options, and other ownership interests) > $5,000 over the past 12 months
  • If non-publicly traded entity, total value of remuneration > $5,000 or any equity interest (including stock, stock options, and other ownership interests) over the past 12 months
  • Income received over the past 12 months related to intellectual property > $5,000 (excluding intellectual property owned by the UC)
  • Any reimbursed or sponsored travel (excluding (1) travel that is reimbursed or sponsored by a US Federal, state, local government agency, a domestic Institution of higher education or a domestic research institute affiliated with an Institution of higher education; and (2) sponsored or reimbursed travel for the Investigator’s spouse/registered domestic partner and/or dependent children)- see Travel Disclosure Process below

SFIs do not include:

  1. Financial interests in mutual funds or other investment vehicles such as retirement funds where the Investigator or the Investigator’s spouse/registered domestic partner or dependent children does not directly control the investment decisions made for these investment vehicles.  
  2. Payments made by The Regents, including salary, stipends, royalty payments, honoraria, reimbursement of expenses, or any other remuneration from the University of California.
  3. Income from seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by a US federal, state or local government agency; a domestic institution of higher education; or a domestic research institute affiliated with a domestic institution of higher education.
     
Definitions
  • Institutional Responsibilities: Teaching/education, research, outreach, clinical service, and University and public service on behalf of the University of California which are in the course and scope of the Investigator’s University of California appointment/employment.
  • Related (Note: Determined by PRO Team): Related financial interests occur when the researcher, their spouse/registered domestic partner or dependent children have a disclosable financial interest that would reasonably appear to be affected by the research or when the entity in which the financial interests are held would reasonably appear to be affected by the research. To assist in the disclosure process, the following examples are provided:
    • The project results could be relevant to the development, manufacturing, or improvement of products or services of the entity in which the researcher has a financial interest;
    • The researcher has a financial interest in an entity that might manufacture, commercialize or license a drug, device, procedure or any other product used in the project or that will predictably result from the project;
    • The researcher received compensation from activities in his/her professional field during the prior twelve months, where the financial interest of the entity or the investigator would reasonably appear to be affected by the project;
    • The researcher has a financial interest in an entity and the project proposes to subcontract a portion of the work, or lease property, or make referral of participants to, or make purchases from the entity; or
    • The researcher has a financial interest in an entity that is part of a consortium or that will otherwise participate in the project.
       
Travel Disclosure Process

All reimbursed or sponsored travel related to Investigator’s Institutional Responsibilities must be disclosed in the DOE Travel Update Form DOE 515, (excluding travel that is reimbursed or sponsored by a US federal, state, local government agency, a domestic institution of higher education or a domestic research institute affiliated with an institution of higher education).  All significant financial interests from a foreign entity (governmental, non-profit, for-profit, etc.) must be disclosed.
 

How do I Submit My Disclosure Forms?

If your research is sponsored by the DOE, you must complete and submit the Financial Disclosure for DOE-Funded Research (Form DOE 500) and complete or have completed the required Ethics and Compliance Briefing for Researchers (ECBR) training.

If you answered yes to any questions on the Form DOE 500, you may need to complete additional documents. The PRO staff will let you know which additional supplemental form you need to complete. NOTE: A “Positive Disclosure” cannot be reviewed without the completed DOE Supplemental Form requested. Failure to submit the completed and signed documents may result in a delay in funding.
 

Training

All UCR Investigators are required to complete the Ethics and Compliance Briefing for Researchers (ECBR) training found on UC Learning Center, every two years to satisfy the UC Ethics and Compliance and PHS/DOE training requirements.

While the CITI Program Training (Collaborative Institutional Training Initiative) entitled “Conflict of Interest” is not required nor accepted as PHS training, the module provides useful information on conflict of interest and objectivity issues.
 

Resources

 

DOE's Disclosure Requirements for Current & Pending Support

  • DOE - Current and Pending Support using SciENcv

    SciENcv - (Updated September 21, 2021) NSF partnered with the National Institutes of Health (NIH) to use SciENcv: Science Experts Network Curriculum Vitae as an NSF-approved format for use in preparation of the current and pending support section of an NSF proposal. 

    Department of Energy has now adopted the NSF-approved format for use in preparation of the current and pending support section of a DOE proposal. Adoption of a single, common researcher profile system for Federal grants reduces administrative burden for researchers. As such, SciENcv will produce DOE-compliant PDF versions of the current & pending support format; however, the requisite DOE Current & Pending Support Certification must also be completed (e.g., insert Name and Title, Sign, and Date).

    Proposers must save these documents as a single-combined PDF and submit them as part of their proposal via CayuseProposal for submission to Grants.gov.

  • DOE - Current and Pending Support using Fillable PDF

    The Department of Energy supports the use of NSF's fillable PDF for preparation of the current and pending support document; however, such PDF does not contain the additional certification required by the DOE.  As such, UCR has taken the NSF-fillable pdf and inserted the requisite DOE certification.  All PIs and other Senior/Key Personnel named in the application (and any proposed subaward level) must each complete a Current & Pending Support document.  In the DOE certification section, please insert Name and Title, and include Signature and Date.

    Note: Proposers should download and save the blank PDF document prior to adding content.

    Both Mac and Windows users are recommended to open and fill in the blank PDF document using Adobe Acrobat Reader for an optimized experience.

    The completed and saved PDF can then be uploaded via CayuseProposal for submission to Grants.gov.

  • Disclosure of Past Support

    In addition to Current & Pending Support, DOE/NNSA program offices may also require disclosure of past support. This should be limited to a reasonable time period (e.g., previous five years), to be determined by the DOE/NNSA program office.

    Disclosure of past support would prevent a scenario where a program office unknowingly funds RD&D that had already been supported, but where the prior award happened to conclude before submission of the application to the DOE Program Office. The requirement to disclose past support will be stated in the applicable funding opportunity announcement. Disclosure of past support may be unnecessary in basic and fundamental research that leads to publications and other forms of scholarly communication.

  • Overview of DOE's Current and Pending Disclosure Requirements

    BACKGROUND

    In January 2021, the White House issued the National Security Presidential Memorandum-33 (NSPM-33), which directed federal research agencies to require principal investigators (PIs) and other senior/key personnel to disclose appropriate information that “will enable reliable determinations of whether and where conflicts of interest and commitment exist.” Around the same time, Section 223 of the FY 2021 National Defense Authorization Act (NDAA), codified at 42 U.S.C. § 6605, was enacted, which requires all federal research agencies collect current and pending support disclosures as part of the application process.

    To ensure consistent implementation of NSPM-33 and Section 223 of the FY 2021 NDAA, on January 4, 2022, the White House Office of Science and Technology Policy issued NSPM-33 implementation guidance, which addressed five key areas, including “Disclosure Requirements and Standardization.” Current and pending support is one piece of the larger category of disclosures.

    Standardizing disclosure requirements is a central theme in the NSPM-33 implementation guidance, and federal research agencies are charged with developing model financial assistance application forms and instructions. While those efforts are underway, the Department of Energy (DOE) is taking this initial step to mandate all DOE and National Nuclear Security Administration (NSSA) offices incorporate consistent current and pending support disclosure requirements to harmonize the type of required information submitted to the Department as part of current and pending support disclosures.

    OVERVIEW OF DOE'S CURRENT & PENDING DISCLOSURE REQUIREMENTS

    The DOE issued Financial Assistance Listing (FAL) #2022-04 on June 1, 2022, directing program officers to implement new disclosure requirements for DOE and NSSA awards. Program officers will implement the provisions in new funding announcements effective immediately.  The new provisions include a certification about the completeness and accuracy of current and pending support, disclosure of past support on an as-needed basis as required in new award announcements, and a reminder about the requirement to disclose participation in foreign talent recruitment programs. (Refer to FAL for specific requirements and definitions.)

    FAL 2022-04 applies to all DOE and NNSA funding opportunity announcements (FOAs), financial assistance agreements (i.e., grants and cooperative agreements) resulting from those FOAs, and financial assistance agreements resulting from unsolicited proposals – that are: 1) issued on or after June 1, 2022; and 2) encompass research, development, and demonstration (RD&D) activities, or technical assistance to support RD&D activities. The current and pending support requirements may also be included in non-RD&D FOAs and awards issued on or after June 1, 2022 if determined necessary by one level above the Grants Officer.  This FAL is not applicable to financial assistance agreements that exclusively fund conferences, workshops, and other technical meetings.

    TWO OPTIONS FOR CREATING THE CURRENT & PENDING SUPPORT DOCUMENT

    Current and Pending Support information may be provided in the format approved by the National Science Foundation (NSF) with the inclusion of the DOE certification. The use of a format required by another agency is intended to reduce the administrative burden to researchers by promoting the use of common formats.   The two approved DOE formats for creating Current & Pending Support are:

    • NSF SciENcv with accompanying DOE certification
    • NSF-Fillable Current and Pending Support PDF (adapted with DOE certification)