Financial Conflict of Interest Policy
Updated: July 15th, 2015
The Public Health Service (PHS), including the National Institutes of Health, has changed its policies regarding financial conflict of interest (FCOI), effective August 24, 2012.
As of August 24, prior to proposal submission the University must obtain information from each proposed subrecipient about whether the subrecipient (1) has their own PHS-compliant financial conflict of interest policy or (2) does not have a policy and will agree to be subject to UW-Madison's policy on financial conflict of interest.
At award setup time RSP will request that all conflict of interest obligations (OAR Disclosure, FCOI Training, Management Plan Reporting) for all personnel listed on the projects tab are completed. Guidance is available at: http://www.grad.wisc.edu/research/policyrp/coi/index.html
Please ensure that all key personnel are correctly entered in the projects tab prior to COI review. You can notify RSP that the key personnel are ready for COI review by:
- Approving the setup projects approval; or
- Submitting comments only to the approval indicating that the personnel section on the projects tab is set
After confirmation of key personnel on the projects tab, RSP will load this WISPER record to FAST (FCOI Award Setup Tool) to being the COI review process.
The COI approval should remain open until all conflict of interest obligations are completed.
See RSP Notice 2013-1 for more information.
FCOI Policy Process Map
Proposal Submission to a PHS Agency with Subaward
- Start a WISPER record. At the bottom of the "General" tab, indicate "Yes" for Outgoing Sub-Agreement question.
- Go to FDP Clearinghouse to verify the subrecipient is listed.
- If listed, in the "Comments" tab of the WISPER record, note subawardee name and indicate they are in the FDP Clearinghouse. Ex. "Univ. of Michigan in FDP Clearinghouse."
- Route WISPER record as normal as nothing else is required.
- If not listed, subrecipient must complete and return the Subrecipient FCOI Documentation Form.
- In the "Comments" tab of the WISPER record, note the subawardee name and indicate the FCOI Documentation Form is attached. Ex. "Univ. of Virginia-FCOI Doc Form attached."
- Attach FCOI Documentation Form to the WISPER record. Suggested naming convention: "institution_FCOIDoc.pdf" Ex. "UVA_FCOIDoc.pdf"
- If subrecipient indicates on the FCOI Documentation Form (Sect.B.1) that they are following their own policy, nothing else is required. Route the WISPER record.
- If subrecipient indicates on the FCOI Documentation Form (Sect.B.2) that they will follow the UW Policy, they must also complete and return the Subrecipient Disclosure of Financial Conflict of Interest Form for each investigator.
- Attach Subrecipient Disclosure of Financial Conflict of Interest Form(s) to the WISPER record. Suggested naming convention: "institution_Discl_InvestigatorLastName.pdf" Ex. "UVA_Discl_Smith.pdf"
- Route the WISPER record.
Electronic Lookup Tools
- FAST (FCOI Award Setup Tool)
- Use this lookup tool to view the setup worklist and status of all FCOI Clearances for PHS awards.
- FCOI Training Status Lookup
- Use this lookup tool to view FCOI training completion status.
- FCOI Documentation Request Letter
- Subrecipient FCOI Documentation Form
- Subrecipient Disclosure of FCOI Form
- Subrecipient NetID Request Form