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";



• The subcontract is a non-profit, tax-exempt, educational institution; or



• The subcontract 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 the PHS or NSF, then the PI must complete an original of the Federal Principal Investigator Certification Form in addition to Form 700-U (unless exceptions for submission of Form 700-U apply), and the PI must list all participants who have financial interest(s) related to the proposed research project. Each participant who is listed must complete an original federal Disclosure of Financial Interests form. Those participants who are not listed do not need to complete a disclosure form.

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 federal certification/disclosure forms from the PI and all the participants. Genentech is a non-governmental entity and is not exempt.



2. UCSF receives a subcontract from American Cancer Society. The ACS receives its funding from NIH. UCSF must collect the federal certification/disclosure forms. The ACS is on the State of California exempt list, and accordingly, the state form does not need to be collected.



3. The federal certification/disclosure forms need to be collected.



4. UCSF received a subcontract from The Parkinson Disease Foundation (“PDF”). PDF receives its funding from the NIH. PDF is a non-profit entity, but it is not on the state exempt list. UCSF must collect both the state form and the federal forms in conjunction with this subcontract.

All required forms must be completed, and the originals must be submitted at the time of proposal submission.

Updated October 2004