Contracts & Grants: Compliance
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Ongoing Compliance During the Life of an Award
Compliance with applicable University, State and Federal Policies is important to maintain throughout the life of an award. Some compliance areas may require annual updates to disclosures or protocols. Dependent upon the specifics of your project, here are a few of the possible compliance areas which may require routine monitoring.
Financial Conflicts of Interest
Please see the Conflict of Interest page for more information on when these forms may be applicable to your project.
- Form 800: All Principal Investigators and other Investigators on projects involving Human Subject Research and in projects sponsored by the NSF, CIRM, UC Discovery Grants and UCOP Special Programs must file an updated Form 800 and Supplemental Form when they (or their spouses/domestic partners or dependent children) acquire a new financial interest related to a project, while the project is receiving financial support.
- PHS FCOI Requirements:
Submission of the PHS Financial Disclosure (Form 1) is required (i) on an annual basis for non-competing continuation awards, (ii) when a new Investigator is added to the project, or (iii) when an Investigator’s financial interests increase, whichever comes first. It is also required when an Investigator transfers PHS-funded research to UC ANR. At the time of the initial award the PI must certify that (i) he/she must submit a PHS disclosure form for any new UC ANR investigator added to this project in the future, and may not use project funds to support any UC ANR investigator who makes a positive disclosure until the UC ANR COI Committee reviews and approves this disclosure, (ii) no UC ANR investigator may participate in this project until the investigator certifies that they have completed the UCOP PHS-FCOI compliant training dated within the last four years.
- Form 700u: For "interim" statements, the filer must submit a statement within 30 days after the contract, grant, or gift is renewed that discloses reportable investments, income and business positions that the filer held or received during the period between the date the initial statement was filed and the date the project contract, grant, or gift was renewed.
The United States export laws and regulations operate to restrict the use of and access to controlled information, goods, and technology for reasons of national security or protection of trade. However, both the EAR and the ITAR exclude fundamental research from the requirements of the regulations. Fundamental research is defined as "basic and applied research in science and engineering conducted at an institution of higher learning in the United States where the resulting information is ordinarily published and shared broadly within the scientific community, as distinguished from research the results of which are restricted for proprietary reasons or specific U.S. Government access and dissemination controls." Information which is publicly available also is excluded from the purview of the export control regulations. To guarantee the application of these exclusions, researchers should publish their findings to the fullest extent possible and should not agree to confidentiality clauses or other terms that restrict the dissemination of research materials and results.
The fundamental research and public domain exclusions do not apply to tangible items that are being taken or shipped outside of the U.S. For example, taking your laptop outside of the U.S. can be subject to export control regulations. In such cases, those items must be analyzed to determine whether they are subject to export controls. For questions on this process, please contact the Office of Contracts and Grants at firstname.lastname@example.org. The process of obtaining an export license from the government can be lengthy, so please plan accordingly.
Export Controls Video Series*:
- Introduction to Export Controls (6 minutes)
- Traveling Abroad (4 minutes)
- Office of Foreign Assets Control (4 minutes)
- International Traffic in Arms Regulations (ITAR) (7 minutes)
- Biological Agents (5 minutes)
*Presentations may not work with the browser Firefox
Environmental Health & Safety Requirements
Human Subjects, Animal Subjects, Quarantined and Regulated Pests, Chemical and Pesticide Safety, Biosafety, and Fieldwork each have specific requirements when it comes to modifying your protocol as well as training requirements for new staff or renewal trainings. As the PI you are responsible for adhering to ANR and/or your affiliated campuses protocol, training policies and safe handling practices in order to maintain compliance throughout the life of the project.
For more detailed information on Environmental Health & Safety Requirements please visit:
- OCG EH&S Compliance Page
- PRINCIPAL INVESTIGATOR EH&S Compliance Quick Guide
- UC ANR Safety Training Resources