Subject: Disclosure of economic interest Date: Thu, 31 Mar 2005 08:35:44 -0600 Message-ID: <568759DC4C96A04492F66C28BBD18032AD593B@lcmail1.ui.uillinois.edu> From: "Williamson, Donna" To: Cc: "McNeely, Donna S" Professor Bernstein: I have reviewed this matter with the Ethics Office, Donna McNeely, as well as within the office of university counsel. I looked at the criteria that was used to select those persons who received the disclosure statement this year and at the facts of your particular situation. While being a PI is not a triggering event in and of itself, the role and activities of a PI trigger the application of the statute in most cases. The operative language under 5 ILCS 420/4A-101(f)(2) is "direct responsibility for the formulation, negotiation,...of contracts entered into by the State in the amount of $5000 or more;." A PI prepares or "formulates" the proposal and the budget which are submitted to the granting agency or entity and which form the terms of the agreement between the parties, i.e., the State (in this case, the university) and the granting party. If the grant(s) is in excess of $5000, then the contract created by submission of the proposal and acceptance by the granting entity meets the minimum requirements of the statute. The Ethics Office used the banner system to determine the threshhold dollar amounts of the grants for those PI's who received statements. It appears, based on the information which I received, that your grants meet this requirement. If you have additional information which you would like to provide to me to refute the application of the statute to your situation, please do so.