Financial Conflict of Interest Policy

Updated: March 27th, 2013

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

FCOI Policy Process Map Workflow

Proposal Submission to a PHS Agency with Subaward

Proposal Submission to a PHS Agency with Subaward Workflow Chart
  1. Start a WISPER record. At the bottom of the "General" tab, indicate "Yes" for Outgoing Sub-Agreement question.
  2. 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.

Electronic Lookup Tools

Forms

Policies

References