Research and Economic Development

National Aeronautics and Space Administration (NASA)

For Research Funded by NASA

Update: NASA published its final conflict of interest policy to be implemented by December 1, 2023 for grants and cooperative agreements. UCR webpages are being updated accordingly.

Reporting Triggers:

  • NSF research contracts and grants
  • NASA grants and cooperative agreements
  • Non‐governmental entity which flows down from NSF/NASA funds
    • Excludes NASA SBIR/STTR subawards
    • Includes NSF SBIR/STTR subawards
  • California Institute for Regenerative Medicine (CIRM) Grant
  • Juvenile Diabetes Research Foundation (JDRF)
  • UC Special Research Programs (HIV/AIDS, Breast Cancer and Tobacco Related Disease)

Who:

  • Investigator(s), who are the individuals responsible for the design, conduct, or reporting of the funded research project, must disclose their significant financial interests. The Principal Investigator is responsible for accurately classifying the individuals on their project based on their roles, and collecting financial disclosures from all project participants that meet the definition of "Investigator."
    • All UCR Investigators, which may include senior personnel and other personnel, are required to complete the Kuali COI Disclosure. Principal Investigators are responsible for determining who meets the definition of an "Investigator" and is required to disclose.
      • NSF Definitions of Categories of Personnel are based on titles - not responsibilities in the funded project. However, the NSF COI Policy requires Principal Investigators/Project Directors to identify individuals as Investigators based on their responsibilities on the project.

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 NSF/NASA compliant research project including:

  • Income (including salary, consulting payments, honoraria, royalty payments, dividends, loans from the entity, or any other payments or consideration with value) > $10,000 (excluding income from seminars, lectures, teaching engagements, or service on advisory committees or review panels for public or nonprofit entities) received in the last 12 months;
  • Equity interest (including stock, stock options, private equity, real estate, or other investment or ownership interests) > $10,000 or 5% ownership interest in entity (Note: Additional questions regarding venture or other capital financing may be asked in cases of 5% or greater equity/ownership interest in private entity); OR
  • Intellectual Property interest in a patent, patent application, or copyright of a software (excluding intellectual property owned by the UC)

When to Disclose:

  • With the initial proposal
  • When a new Investigator(s) is added
  • With any change in an investigator’s financial interest

Definitions:

  • Related: Work to be performed under the sponsored project and results therefore that would reasonably appear to affect the Significant Financial Interest of the Investigator or the financial interests of the entity in which the Investigator has a financial interest. Consistent with federal regulations, the following examples are financial interests that are considered "related" to a sponsored project:
    • The Investigator is conducting a project where the results could be relevant to the development, manufacturing, or improvement of the products or services of the entity in which the investigator has a financial interest;
    • The Investigator has consulting income in his/her professional field that exceeded $10,000 from a single entity during the prior twelve months, where the financial interest of the entity or the Investigator would reasonably appear to be affected by the federally-sponsored research;
    • The Investigator has a financial interest in an entity and the sponsored 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 Investigator has a financial interest in an entity that is part of a consortium or that will otherwise participate in the sponsored project.

References: