The U.S. Department of Energy (DOE) requires disclosure of significant financial interests by investigators who participate in DOE or National Nuclear Security Administration (NNSA) funded research either directly or by subaward.
At the proposal stage the Principal Investigator (PI) must fill out the Conflict of Interest screening questions in SPO's Proposal Submission Request webform on behalf of all investigators that will be involved in the project.
If any investigator prompts the PI to respond “yes” to any of the screening questions, the investigator will be required to complete and submit the DOE Financial Disclosure Form to the COI Office at coi@ucmerced.edu for review prior to the award being released.
To Whom does the DOE Conflict of Interest (COI) policy apply?
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-UCM personnel, postdoctoral fellows and students depending on their responsibilities for the funded research.
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.
What must be disclosed under the DOE COI policy?
Investigators must disclose the following Significant Financial Interests (SFI) 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 (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:
- 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.
- Payments made by The Regents, including salary, stipends, royalty payments, honoraria, reimbursement of expenses, or any other remuneration from the University of California.
- 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. .
Sponsored or Reimbursed Travel
DOE-funded Investigators are required to disclose sponsored or reimbursed travel that is related to their institutional responsibilities. Reimbursed travel involves instances where the Investigator is directly reimbursed by a non-UCSB entity for the Investigator’s travel expenses. Sponsored travel involves situations where an Investigator’s travel is paid directly by the external sponsoring entity and is not reimbursed to the Investigator.
There are a number of exceptions to the travel disclosure requirement. Please note, the following exceptions do not apply to foreign travel. You are not required to disclose travel that is reimbursed or sponsored by a domestic:
- Federal, state, or local government agency;
- institution of higher education as defined at 20 U.S.C. 1001 (a);
- academic or teaching hospital;
- medical center; or
- research institution that is affiliated with an institution of higher education.
When are disclosures required?
- 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.)
DOE Financial Disclosure Training Requirement
All Investigators are required to take DOE-compliant training prior to engaging in research projects wholly or in part funded under DOE financial assistance awards for all new awards and at least every four years while engaging in DOE-funded research. The training requirement must be met as follows:
UC Ethics and Compliance Briefing for Researchers (ECBR) is available for UC Merced researchers with a UCM ID through the UC Learning Center. Note that all UC extramurally funded researchers must complete this ECBR training (whether or not they have also completed other DOE-specific training) to satisfy Regentally mandated COI training.
Go to the UC Learning Center, login with your UCM ID, and search for UC Ethics and Compliance Briefing for Researchers.
Go through the training slides to complete the course.
After you have completed the training, you will receive a certification email. Keep this email for your records.
