July 27, 2017

What SPO Requires: PHS FCOI

Proposals submitted to and awards funded by Public Health Service (PHS) sponsors (and sponsors that have adopted PHS financial conflict of interest (FCOI) regulations) must follow specific campus procedures to ensure UC Berkeley conforms to the PHS FCOI requirements.

Due to improvements brought about by the campus’ End-to-End (E2E) review of research administration services, these campus requirements recently have been streamlined, and the PHS FCOI Guide for CSS/Department Research Administrators and Principal Investigators on the SPO website has been updated to reflect these improvements.

Notable changes include:
  • Elimination of the need to submit a Form 5 for each subrecipient investigator at the proposal stage. Required information is now supplied by the subrecipient’s authorized official via the current Subrecipient Commitment Form.
  • Retirement of the PI Certification Form at the proposal stage and throughout the life of the award. The information on the PI Certification Form is now included in the Principal Investigator and Co-Investigator Certification provided on the PI and Co-PI approval screen in Phoebe Proposal Development.
Please note: Each time a PI/Co-PI approve a proposal in Phoebe that is being submitted to a PHS sponsor or a sponsor that has adopted PHS FCOI requirements, the PI and Co-PI are certifying and agreeing to the following:
  • All required PHS Financial Disclosures have been submitted to the Sponsored Projects Office (SPO).
  • I will submit a PHS disclosure form for all existing investigators annually and for any new UC Berkeley investigator I add to this project in the future before the investigator joins the project.
  • I will not use project funds to support any UC Berkeley investigator who makes a positive disclosure until the UC Berkeley Conflict of Interest (COI) Committee reviews and approves this disclosure.
  • I will not allow any UC Berkeley investigator to participate in this project until the investigator provides me with a certificate of completion of PHS-compliant training dated within the last four years.
  • I will maintain a file containing up to date certificates of PHS-compliant training for all UC Berkeley investigators for as long as each investigator is involved in the project and to make this information available to the UC Berkeley’s COI Coordinator upon request. PIs and Co-PIs always should make sure that have provided all required disclosures to SPO and that they understand these requirements before approving the proposal.