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Disclosing Financial Interests: Federal (Non-PHS) Sponsored Research

See financial interest reporting requirements for  federal (non-PHS) sponsored research.

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Overview

Beginning in 1995, federal regulations, as well as the University of California policy's on disclosure of financial interests and the management of conflicts of interests related to sponsored projects, began requiring researchers at UCSD, who receive funding from a particular federal sponsor, to disclose certain significant financial interests. Significant refers to specific financial thresholds, as well as the researcher's financial interests or the financial interests of the entity, that could reasonably appear to be affected by the federal sponsored research.

The UCSD-created 9510 Form is the Disclosure of Financial Interests Related to Federal and Other Sponsored Projects Adopting the Federal Requirements, and is used for the disclosure of significant financial interests when projects are being funded by specific federal sponsors.

Keep in mind that having an outside financial interest is not automatically a conflict of interest. It is also important to remember that some financial interests are of such low value and/or limited duration that they do not meet the definition or threshold of disclosable financial interests, or are so small or inconsequential that the research support from the sponsor can be accepted with no further action. And, almost all disclosed financial interests and resulting conflicts of interest can either be reduced, eliminated, or managed so that the research project can be accepted and funded by the proposed sponsor.

When is disclosure required?

The 9510 form is required at the time of submission for any proposal being submitted to:

  • National Science Foundation (NSF)
  • California Institute for Regenerative Medicine (CIRM)
  • UC Discovery Grant Programs:
    • bio - Biotechnology
    • com - Communications and Networking
    • dig - Digital Media
    • ele - Electronics Manufacturing and New Materials
    • itls - Information Technology for Life Sciences
    • MICRO - Microelectronics
  • UC Programs:
    • Breast Cancer Research Program (BCRP)
    • California HIV/AIDS Research Program (CHRP)
    • Tobacco-Related Disease Research Program (TRDRP)
  • Subawards:
    • When a project is awarded through a subaward and the funds originating from NSF, UC Discovery Grant Program, and UC Programs BCRP, TRDRP, and UARP.

For projects funded by the NSF and other sponsors who have adopted the NSF policy, the 9510 form is required with:

  • Initial proposal
  • Renewal proposals
  • Annually or with any change in the investigator's financial interest(s)

For Federal projects that are not NSF (or have sponsors who have not adopted the NSF policy), the 9510 form is required with:

  • Initial proposal
  • Continuation proposals (if required)
  • Renewal proposals
  • Supplemental proposals
  • When new personnel are added
  • Any change with the investigator's financial interest(s)

When is disclosure not required?

The 9510 form is not required for:
  • Training Grants
  • Other Federal Agencies:
    • NASA
    • Air Force
    • Army
    • Department of Defense (DOD)
    • Department of Education
    • Department of Energy (DOE)
    • Department of the Interior (DOI)
    • Environmental Protection Agency (EPA)
    • National Endowment of Humanities (NEH)
    • National Oceanic and Atmospheric Administration (NOAA)
    • Office of Naval Research (ONR)
    • United States Geological Survey (USGS)
    • United States Institute of Peace (USIP)
  • UC Discovery Opportunity Awards
  • UC Programs other than BCRP, TRDRP, and UARP
  • Foreign Governmental Entity

Be sure to check with your proposal analyst for other specific agencies not listed above.

Who is required to disclose?

The researcher at UCSD is not the only individual who must disclose their significant financial interests; all other individuals who have responsibility for the design, conduct, or reporting of research results for the sponsored project must also disclose their financial interests. These individuals can include: 
  • Co-Principal Investigators
  • Other Investigators
  • Other individuals participating in the project

Please Note: Financial interests must be reported for the disclosing individual(s) and their spouse and dependent children. If any of these individuals make a positive financial interest disclosure, meaning a financial interest may exist due to the information that was disclosed on the 9510 form, a conflict of interest Addendum form must also be completed by that individual or individuals. The Addendum provides the opportunity for the individual to more fully describe their financial interest and indicate whether the project could directly and significantly affect the financial interest.

What financial interests must be disclosed?

A financial interest refers to the direct financial relationship between the researcher and an entity OTHER than the federal sponsor. This is also referred to as a related financial interest and only applies to entities that could benefit from the results of the federal sponsored project. Some examples of this include:
  • Equity holdings in the entity
  • Management position with the entity
  • Consulting income received from the entity
  • Honoraria received from the entity

In general terms, significant financial interests that must be disclosed can be separated into 4 main categories. These categories include, but are certainly not limited to:

Income from the entity:

Income of $10,000 or more from a single for-profit company or non-profit foundation, for services that can include: salaries, consulting income, honoraria from speeches or other services that were performed, royalty payments, and stock dividends and/or interest earned, or the proceeds from any stock sales. In addition, income also includes compensation received by the University of California Health Sciences Compensation Plans.

Investments in the entity:

Investments in the entity can include stocks, bonds, stock options, including margin or brokerage accounts or loans.

  • For publicly traded entities: these investments are defined as having a market value of $10,000 or more, or exceeding a 5% ownership interest.
  • For privately held entities: these investments are based on the amount of the investment, not market value, of either $10,000 or more or exceeding a 5% ownership interest.

Positions with the entity:

Positions with the entity, which can include positions as founder, partner, director, manager, officer, trustee, employee, or any other position of management with the entity.

Intellectual Property:

Intellectual property interest, meaning any invention, discovery, or work of authorship, in a patent, patent application, or a copyright assigned or licensed to a party other than The Regents of the University of California.

Please Note: These 4 financial interest categories above each use a 12 month threshold for financial disclosure, but it is applied in different ways. For example:

  • Income uses the 12 month threshold in 2-ways: for activities that took place 12 months prior to the time of financial disclosure, as well as for 12 months of future or anticipated financial interest.
  • Investments, Positions, and Intellectual Property applies only to current, as well as for 12 months of future or anticipated financial interest.

What financial interests do not need to be disclosed?

  • Payments made by The Regents of the University of California, including salary, stipends, royalty payments, honoraria, reimbursement of expenses, or any other remuneration from the University.
  • Income from seminars, lectures, teaching engagements, or service on advisory committees or review panels of public and non-profit entities.
  • Financial interests not related to the sponsored project. For example, a computer scientist conducting research on computer-aided drug design does not need to disclose financial interests (stock in companies such as IBM or Xerox) if these companies are not conducting research or manufacturing in the field of computer-aided drug design.
  • Financial interests unrelated to their field of research, such as Wal-Mart stock or real estate investments.

Where do I submit the 9510 form?

Submit the 9510 form with the funding proposal to:
  • Office of Contract and Grant Administration (OCGA) for General Campus and Health Sciences proposals including:
      • Research Contracts and Grants
      • Investigator-Initiated Protocols
  • Scripps Institution of Oceanography Contract and Grant Office for SIO proposals including:
      • Research Contract and Grant
      • Industry Service Agreements
      • Purchase Orders

Please Note: An original signature is always preferred, however faxed signatures will be accepted.

What happens after the 9510 form is submitted?

  • The proposal review office sends the 9510 form to the Conflict of Interest (COI) Office.
  • If no financial interest exists, then 9510 form is approved. This is referred to as a Negative Disclosure. The COI Office informs the proposal review office to release funds upon receipt of the award.
  • If a financial interest exists, this is referred to as a Positive Disclosure:
    • The 9510 form and the Addendum are forwarded to the Independent Review Committee (IRC) for further review
    • The IRC recommends a conflict of interest management strategy to the chancellor
    • Chancellor either endorses or disagrees with the recommended strategy
    • Memo is issued by the Conflict of Interest Office advising the researcher of the Chancellor's decision

Please Note: Once the disclosure of financial interests forms have been submitted, they can be made available, upon request, to the public, under the California Public Records Act.

What happens if I am required to submit the 9510 form and do not?

Failure to file or update economic interests forms or to comply with any conditions or restrictions imposed on the conduct of the project will be grounds for discipline under the University Policy on Faculty Conduct and the Administration of Discipline and/or other applicable employee discipline policies. Furthermore, federal sponsors may suspend or terminate the award and/or debar an investigator from receiving future awards.

Conflict of Interest Examples and Scenarios:

To assist you with a better understanding of what a conflict of interest may look like for a researcher here at UCSD, and how they may occur, let's take a look at a couple of basic, straight-forward federal examples and/or scenarios.

Scenario #1:

Dr. Serena Drysdale's research focus is inorganic nanotechnology. Dr. Drysdale is a member of the Scientific Advisory Board for Nanosys, a company the manufactures high performance inorganic nanostructures for the use in fuel cells and flat-panel displays. The department of Nanoengineering received a $3 million National Science Foundation (NSF) grant to research nanostructures for use in MP3 players and digital cameras. Dr. Drysdale will be the co-principal investigator on this project.

  • Does Dr. Drysdale have a financial interest that may result in a potential conflict of interest?

  • Yes, Dr. Drysdale is a member of the Scientific Advisory Board and thus is able to influence the research focus of Nanosys. Nanosys could also benefit from the research results of this NSF project. In addition, Dr. Drysdale's research field, the nature of her research project, and Nanosys products are all related.

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