Disclosing Financial Interests: Material Transfer Agreements

A Material Transfer is the transfer of tangible research materials between UCSD and other entities to conduct scientific research. They are used to support an investigator's independent or collaborative research through the use of novel, tangible, research tool, or material.

Some of the most frequently transferred materials include reagents, cell lines, plasmids, and vectors. However, material transfers may also include: chemical compounds, software, databases, gene chips, and small devices. Examples can include:

• A UCSD investigator wishes to receive a plasmid from an organization to test the effects of mutations isolated in a yeast expression system.
• A UCSD investigator wishes to send Poly(tetraphenyl)silole to an organization to evaluate in a chemical sensor array to determine its value in the detection of various chemicals.

700-U Form:

The State of California's Fair Political Practices Commission requires disclosure of financial interests by using the State of California's Statement of Economic Interest for Principal Investigators, or the 700-U form. Keep in mind that all financial disclosures must also be updated during the entire period of the award, as new reportable significant financial interests occur.

In addition, the required UCSD Material Transfer form for sending or receiving material includes a question which asks about your financial realtionship with the entity. If your response is "Yes" additional paperwork, the 700-U form and the Addendum will need to be completed for conflict of interest review.

The 700-U form must be filled out in its entirety by the principal investigator who must disclose their financial interests; as well as the financial interests of their spouse or registered domestic partner, and/or their dependent children.

Addendum:

If a positive financial interest is disclosed, meaning a conflict of interest may exist due to the information that was disclosed on the 700-U form, a conflict of interest Addendum form must also be completed by the principal investigator. The Addendum provides the opportunity for the principal investigator to more fully describe their financial interest and indicate whether that financial interest could directly and significantly affect the sponsored project.

Financial interests are the most important component or components of a conflict of interest for researchers. In broad terms, financial interests can be defined as anything of economic value; including a fiduciary relationship with an outside entity. Some examples include, but are certainly not limited to:

• Salaried or unsalaried positions with the entity
• Scientific advisory board memberships
• Vested or non-vested stock or stock options
• Gifts
• Loans
• Travel reimbursements
• Income received through honoraria or consulting

A financial interest refers to the direct financial relationship between the principal investigator and the entity, or indirectly through their spouse, their registered domestic partner, or their dependent children. Some examples of this include:

• Equity holdings in the entity
• Management positions with the entity
• Consulting income received from the entity
• Honoraria received from the entity
• Principal investigator's spouse or registered domestic partner being an employee of or having a financial interest in the entity

The principal investigator at UCSD must disclose their financial interests; as well as the financial interests of their spouse or registered domestic partner, and/or their dependent children. In general terms, financial interests that must be disclosed for the research can be separated into 6 main categories, and are only for activities that took place 12 months prior to the time of financial disclosure. These categories include, but are certainly not limited to:

Positions with the Entity:

These can include positions as founder, partner, director, manager, officer, trustee, employee, or any other position of management with the entity within the past 12 months.

Investments in the Entity:

Investments in the entity, within the past 12 months, can include stocks, bonds, warrants, and stock options, including margin or brokerage accounts that have a value totaling $2000 or more.

Income from the Entity:

Income received from the entity within the past 12 months, which 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.

Gifts from the Entity:

Gifts from the entity, which includes the gift or the promise of a gift received from the entity of $50 or more, or multiple gifts from a single entity totaling $50 or more, within the past 12 months. Keep in mind that it is the acceptance of the gift, not the ultimate use of the gift, that imposes your obligation to disclose. Therefore, you must disclose the personal gift even if you never use it or even if you give it away to another person. If the exact amount of the gift is not known, you must make a good faith estimate of the item's fair market value. Some common examples of disclosable gifts include; tickets or passes to sporting or entertainment events, or amusement parks, parking passes, transportation and lodging, and forgiveness of a loan received by you from the entity.

Loans from the entity:

Loans from the entity require disclosure if the outstanding balance has exceeded $500 within the past 12 months. This also includes community property interest in loans received by the spouse or registered domestic partner.

Travel Reimbursements from the entity:

Travel reimbursement from the donor for travel expenses within the past 12 months, which includes per diem, payments for transportation, travel advances, lodging, and meals that were received from the donor.