Subcontracts

When UCSF is the recipient of a subcontract, the principal investigator at UCSF must complete "Statement of Economic Interests for Principal Investigators" (FPPC Form 700-U), unless an exception applies.

The Form 700-U does not need to be completed if: the subcontract is from a non-governmental entity that is on the “List of Non-Governmental Entities Exempt From Disclosure Requirement"; is from a non-profit, tax-exempt, educational institution; or is from a governmental agency.

Examples of non-governmental entities are a private company, a non-profit entity, and a private university.

Where UCSF receives the subcontract from a sponsoring entity that receives its funding under a prime funding award from any federal agency, or agency that has adopted the federal regulations, then the UCSF PI must complete the electronic disclosure in addition to Form 700-U (unless exceptions for submission of Form 700-U apply), and each researcher who has responsibility for the design, conduct, and reporting of the study must complete a disclosure electronically.

Here are four examples of which forms to complete under various subcontracts:

  1. UCSF receives a subcontract from Genentech. Genentech receives its funding from NIH. UCSF must collect both the state form (Form 700-U) from the PI at UCSF, and the disclosures from the PI and all UCSF researchers who have potential conflicts. Genentech is a non-governmental entity and is not exempt.
  2. UCSF receives a subcontract from The Robert Wood Johnson Foundation (the “RWJ Foundation”). The RWJ Foundation receives its funding from NIH. UCSF must review disclosures of UCSF key personnel. The RWJ Foundation is on the State of California exempt list, and accordingly, the state form does not need to be collected.
  3. UCSF receives a subcontract from The Parkinson Disease Foundation (“PDF”). PDF receives its funding from the NIH. PDF is a non-profit entity, and it is not on the state exempt list. UCSF must collect both the state 700-U form from the Principal Investigator and the federal disclosures in connection with this subcontract.
  4. UCSF receives a subcontract from The Parkinson Disease Foundation (“PDF”). PDF receives its funding from The Michael J. Fox Foundation (the “Fox Foundation”). Both PDF and the Fox Foundation are non-profit entities and are not on the state exempt list. UCSF must collect the state 700-U form for both entities.

All disclosures must be completed, and submitted at the time of proposal submission.