The Office of Grants and Contracts may not submit proposals to NIH, other Public Health Service agencies, or other non-federal sponsors which follow the PHS Conflict of Interest (COI) policy if the budgets include key or senior personnel who have not filed a COI Disclosure with the COI Office.
All proposals will be reviewed in PreAward following normal procedures. At the time of PreAward review, if it is determined the proposal budget includes key personnel who have not filed a COI Disclosure or updated a COI Disclosure within the UCD normal time frame, the proposal will be returned to the PI/administrative contact requesting the disclosure be filed with the UCD COI Office prior to the submission deadline.
Key/ Senior personnel include the Project Director/Principal Investigator and any other person who is responsible for the design, conduct and reporting of basic, animal, or clinical research, this includes PRAs, or anyone who obtains informed consents, those who determine eligibility, and those who review data or conduct data analysis.
Non-Federal Sponsors Grants and Contracts will follow the same procedure for non-federal sponsors which follow the PHS FCOI policy. This means that if an agency follows the PHS FCOI policy, all key personnel will need to a COI disclosure on file with the Office of Regulatory Compliance before the grant may be submitted to the agency. For more information visit the Office of Regulatory Compliance.
Don’t put your proposals at risk by waiting until the proposal submission deadline to file a COI Disclosure! Be sure COI Disclosures are filed now and updated on an annual basis. Federal regulations prohibit Grants and Contracts from submitting proposals that include key/senior personnel in budgets who have not filed or updated their COI.
Print the document: PHS/NIH Rules for Subrecipients
If a subcontracted organization has a COI policy and process, UCD will rely on that organization’s policy to satisfy this regulatory process. Each subcontract will include UCD’s requirements of the organization to fulfill the COI responsibilities.
If a subcontracted organization does not have a COI policy and process, UCD will require key personnel from the subcontracted organization to file a COI disclosure through the UCD Conflict of Interest Office. This process will be a requirement included in the subcontract.