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

• Interim Department of Energy (DOE) Conflict of Interest Policy
• FAQ Interim COI Policy September 2022
• University of California – Policy PHS COI: Disclosure of Financial Interests & Management of Conflicts of Interest, Public Health Service Research Award
• DOE COI Forms
• DOE Interim FCOI Policy Presentation