Office of Research, UC Riverside
Office of Research Integrity

Promoting Research Objectivity (PRO) Committee - formerly the Conflict of Interest Committee

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About PRO

Investigators at UC Riverside are subject to UC system-wide policies, as well as specific State of California law and federal regulations. Reporting to the Vice Chancellor for Research and Economic Development, the faculty Promoting Objectivity in Research Committee (formally known as the Conflict of Interest Committee), is responsible for the review and assessment of all financial disclosures related to research projects at UC Riverside, as well as determining any actions required to ensure that real or perceived financial conflicts of interest are managed, reduced or eliminated. Their primary goal is to promote research objectivity by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under relevant grants, cooperative agreements and contracts will be free from bias resulting from investigator financial conflicts of interest.

The ORI research staff provides support for UCR researchers and the PRO committee to facilitate and promote compliance with University, state, and federal policies and regulations regarding financial interests related to the objective conduct of research, including Public Health Service (PHS) and National Science Foundation (NSF).


What is a Conflict of Interest?

A Conflict of Interest (COI) is a situation where an investigator's outside financial interests (e.g., salaries; consulting income; receipt of income from intellectual property rights; equity interests; ownership of equity in publicly or privately held businesses; honoraria; gifts; loans; or travel payments) or paid or unpaid obligations (e.g., director, officer, partner, consultant or manager of an entity) bias or have the potential to bias a research project. This also applies to the immediate family members of that investigator. When a financial interest constitutes a Financial Conflict of Interest (FCOI), PRO will work with the disclosing individual to develop a management plan, if applicable, before the disclosure can be approved.

Please note a conflict of interest is not 1) research misconduct, 2) evidence of wrongdoing, 3) indication of moral weakness, or 4) prohibited by law, regulation, or policy.

Be aware that not all outside financial interests are necessarily conflicts of interests in research. The University recognizes outside financial interests can facilitate opportunities for innovation, collaboration, and support. Federal, state, and university regulations and policies requiring financial disclosure and review were implemented to address those instances when the outside financial interests may bias or appear to bias the research. In addition to promoting transparency and accountability, financial disclosures also protect the researcher’s interests by 1) meeting the requirements set by sponsors and the University, 2) having the PRO Committee, an objective third party, review the financial interests and the research, and 3) demonstrating a commitment to scientific integrity.

In terms of financial interest and disclosing, there are three different levels of reporting and each has different reporting requirements:

 

arrow-purple Non-governmental Sponsor (State Law)

 

arrow-green Public Health Service & Organizations following PHS Regulations and

 

arrow-blue National Science Foundation & Organizations following NSF Policy

 

When do I Disclose?

For Research Funded by Non-governmental Sponsors (State Law)

  • Who Discloses:
    • All persons employed by UC who have principal responsibility for a research project if the project is to be funded or supported, in whole or in part, by a contract or grant (or other funds earmarked by the donor for a specific research project or for a specific researcher) from a non-governmental entity.
  • When to Disclose:
    • With the initial proposal (Standard proposals or Industry sponsored research proposals.
  • What to Disclose:
    • Income ≥ $500
    • Investments ≥ $2,000
    • Director, Officer, Employee, Partner, Trustee, Consultant or Management position
    • Loan Balances ≥ $500
    • Personal Gifts Valued at ≥ $50
    • Travel Reimbursements

For Research Funded by the Public Health Service or Organizations Following PHS Regulations

  • Who Discloses;
    • All individuals "with responsibility for the design, conduct or reporting of the research" must disclose the “significant” and “related” financial or management interests to the research described in the proposal for themselves, their spouses/registered domestic partners, and their dependent children.
  • When to Disclose:
    • With the initial and renewal proposals
    • With supplemental funding proposal
    • With non‐competing continuation
    • With no cost time extension
    • When new personnel are 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: A significant financial interest related to the investigator’s institutional responsibilities including:  
    • If publicly traded entity, total value of compensation and equity interest > $5,000
    • If non-publicly traded entity, total value of compensation > $5,000 or any equity interest
    • Income received 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 Federal, state, local government agency, an Institution of higher education as defined by 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a 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.)

For National Science Foundation & Organizations following NSF Policy

  • When to Disclose:
    • With the initial proposal
    • When new personnel are added
    • With any change in an investigator’s financial interest
    • Or at least annually
  • What to Disclose: A significant financial interest related to the research project including:
    • Income > $10,000 (excluding income from seminars, lectures, teaching engagements, or service on advisory committees or review panels for public or nonprofit entities)
    • Equity interest > $10,000 or 5%
    • Intellectual Property interest in a patent, patent application, or copyright of a software (excluding intellectual property owned by the UC)


What is the PRO Conflict of Interest Review Process?

The PRO committee is comprised of faculty from throughout the campus and is advisory to the Vice Chancellor for Research and Economic Development (VC-RED). They make recommendations to the VC-RED to accept an award or to manage, reduce or eliminate conflicts of interest in order to preserve objectivity in the design, conduct or reporting of research. The PRO committee meets once per month on an as-needed basis (i.e., if there are disclosures to review). In order for the PRO committee to review the disclosure and recommend an adequate management/monitoring plan, please submit your disclosures well in advance of your anticipated start date.

For a more detailed summary of the thresholds, please see the UCR COI Disclosure Chart.

Schedule of PRO Meetings & Submission Deadlines for Full Committee Reviews:

PROdeadlines

Depending on the complexity associated with your research, ORI will categorize your submission for review. Applications will be reviewed on a first-come, first-serve basis. Therefore, the ORI highly recommends accurate, thorough, and timely submission of your attachments to account for this review process.

There are three levels of conflict review performed by the office: administrative, delegated and full committee reviews.

PROreviewTimelines.png

Most reviews are completed by Research Integrity staff, including all negative disclosures. In the event of a positive conflict of interest disclosure, Research Integrity staff will request additional background information and determine if it should go to the PRO Committee for review and management.

PROprocess

 

Researchers should plan to submit the disclosure forms well in advance of any anticipated study start and address those issues raised during the review and approval process.


How do I Submit My Disclosure Forms?

Depending on the type of research funding you have obtained and/or your outside interests in addition to your research, different forms will be required. See each section below as it relates to the type of research funding obtained.

Positive disclosures may not necessarily result in full PRO committee review. As noted above, there are three levels of conflict review performed by the office, administrative, delegated and full committee reviews. Most reviews are completed by Research Integrity staff, including all negative disclosures. In the event of a positive conflict of interest disclosure, Research Integrity staff will request additional background information and determine if it should go to the PRO Committee for review and management.


For Research Funded by Non-governmental Sponsors (State Law)

Only the Principal Investigator (PI) and co-PI complete and submit a 700-U Form per project. This disclosure will be valid for the life of the project, unless there are any changes to the funding amounts, term of the funding or PIs. Completion of the 700-U Form is not required if the State has placed the sponsor on the Exempt List. If the sponsor is not on the exempt list, the PI and /or Co-PI must:

  • Complete and sign a Form 700-U
  • Submit the originally signed Form 700-U (This is required by the State)
  • If you answered yes to any questions on the Form 700-U, you must also complete and submit the UCR COI Addendum for Positive 700-U and NSF 925. NOTE: A “Positive Disclosure” cannot be reviewed without the completed COI Addendum Form. Failure to submit the completed and signed COI Addendum Form may result in a delay in funding.

For Research Funded by the Public Health Service or Organizations Following PHS Regulations

If your research is sponsored by a PHS agency or an entity that has adopted the PHS rules, you must complete and submit the Financial Disclosure for PHS-Funded Research (Form 500) and complete, or have completed the required PHS COI training. Please see the list of sponsors that require compliance for PHS Regulations. This list of PHS agencies is taken from the U.S. DHHS Organizational Chart. Because there may be changes, if the agency you are interested in is not on this list and you are unsure if it is a PHS agency, check with the Office of Research Integrity.

If you answered yes to any questions on the Form 500, you must also complete and submit the Supplemental Form 510 and if need be, Form 520. The RI staff will let you know which additional supplemental form you need to complete. NOTE: A “Positive Disclosure” cannot be reviewed without the completed PHS Supplemental Form. Failure to submit the completed and signed PHS Supplement Form may result in a delay in funding.


For National Science Foundation & Organizations following NSF Policy

If your research is funded by one of the government/public entities listed below, all investigators must complete and submit a Disclosure Form for NSF Conflict of Interest Policy (Form 925).

  • National Science Foundation (NSF)
  • California Institute for Regenerative Medicine (CIRM)
  • UC Discovery Grants
  • UCOP Special Programs

If you answered yes to any questions on the Disclosure Form for NSF Conflict of Interest Policy (Form 925), you must also complete and submit the UCR COI Addendum for Positive 700-U and NSF 925. NOTE: A “Positive Disclosure” cannot be reviewed without the completed COI Addendum Form. Failure to submit the completed and signed COI Addendum Form may result in a delay in funding.


Education and Training

    For 700-U (State): There is no required COI training for investigators.
    For NSF: There is no required COI training for investigators.
    For PHS: PHS COI required training is through the UC Learning Center system, entitled “Compliance & Conflict of Interest for Researchers Briefing (COIR)” and required every 4 years for all PI’s that have, or are listed on a PHS award.

    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.

     

    Contact Us:

    If you have questions, the Office of Research Integrity recommends you consult and engage our office as soon as possible.

    Please email us at PRO@UCR.EDU to set up an appointment.

    University of California, Riverside
    Office of Research Integrity
    900 University Ave.
    213 University Office Building

    PRO@UCR.EDU
    Riverside, CA 92521 
    Phone: 951-827-4802

    Where can I find additional information?

    Researchers and committee members can find more information in the PRO section of the ORI Resources Page.

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