Procedures for Expedited Review of Academic Disclosures

After considerable discussion and review, the University of California Office of the President (UCOP), campuses, and Lawrence Berkeley and Lawrence Livermore National Laboratories agreed in 1988 to implement a proposed streamlined approach to the academic disclosure review and documentation process. This approach includes 1) implementation of expedited review and documentation procedures for certain agreed-upon categories of financial disclosure, and 2) reduced documentation of disclosures reviewed under non-expedited review procedures. The California Fair Political Practices Commission (FPPC) has stated its support for this streamline effort upon the recommendation of FPPC General Counsel who has reviewed and discussed this streamline approach extensively with UCOP staff.

Expedited review procedures may be implemented for the following kinds of positive disclosures:

1. Renewal of funding with no change or a reduction in (PI) financial involvement, and no material change in the terms under which the research is being conducted.
2. Completion statements with no change or a reduction in PI financial involvement.
3. PI involvement is limited to membership on sponsor scientific advisory board or the equivalent.
4. PI involvement is limited to income between $250 and $1000 and the income is not derived from consulting related to the project being funded.
5. PI involvement is limited to an investment between $1000 and $10,000 in a publicly-traded stock.

In these situations a consent agenda may be submitted for ISRC committee review and recommendation, listing all disclosures recommended for expedited review with the applicable expedited review categories and basic disclosure information*. The consent agenda would be accompanied by a 730-U and basic supplemental information describing PI research and involvement with sponsor for each disclosure listed. Any additional backup materials on expedited review disclosures would be kept in the campus/lab files.

Committee members and/or staff may choose to have some disclosures receive full non-expedited committee review even though they may be eligible for expedited review.

Under streamline procedures for non-expedited review, committees would continue to review all relevant disclosure materials regarding the particular circumstances of the research being conducted and PI involvement with sponsor in light on the central principles and questions set out in the University Policy and Guidelines.

After committee review, recommendation and approval by the appropriate research official, the documentation kept in the campus/laboratory files would include a summary of committee conclusions and basic disclosure information, an approval letter/signature of appropriate campus research official, a copy of a signed and completed 730-U disclosure statement, and a copy of supplemental information describing research as well as nature and extent of PI involvement in sponsor.

The materials reviewed by the committee would remain in the campus files, such as research proposals, research agreements, consulting agreements, most correspondence, curriculum vitae and publication reprints as well as copies of checks, cashier records, contract and grant forms, and letters of thanks and acknowledgement.

May 24, 1989
Revised as of August 2, 1993