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If you are a Subrecipient Authorized Organization Official OR subrecipient investigator OR consultant investigator, please complete Form A via the electronic . This form must be on file before the University of ºÚ¶´ÉçÇø can submit a proposal containing your proposed subaward.

Please note: for projects subject to the PHS Objectivity in Research regulation, if your institution is a proposed subrecipient and is on the on our website list of institutions with a PHS-compliant Conflict of Interest (COI) policy, you do NOT need to submit Form A. Per the regulation, you must report any FCOI to the University of ºÚ¶´ÉçÇø in the timeline specified in 42 CFR Part 50. In contrast, each consultant considered to be an Investigator (anyone responsible for the design, conduct or reporting of the research) must submit Form A as a declaration of whether s/he is following his/her own institution's compliant COI policy or the University of ºÚ¶´ÉçÇø's COI Policy.

If, and only if, you or an Authorized Organizational Official at your institution indicates on Form A that the University of ºÚ¶´ÉçÇø's COI Policy will be followed (because your organization does not have its own NSF or PHS-compliant COI policy), then EACH subrecipient Investigator (defined as a person responsible for the design, conduct or reporting of the research proposed under the subaward) must be listed on Form A and complete Form B, the financial disclosure form.

Form A will prompt you to "Notify All" Investigators listed, which will send a system-generated email with a personalized link to Form B to each Investigator. If you are a consultant and you are not affiliated with an institution that has a NSF or PHS-compliant COI policy, then you must list yourself as an Investigator on Form A and complete Form B, as well. As part of Form B, each Investigator must certify that they have completed USF's Financial Conflict of Interest Training for Subrecipients (PDF). Training must be repeated at least every three years.

For projects subject to the PHS Objectivity in Research Regulation, if you or the Authorized Organizational Official indicates that your institution's COI policy will be followed, and if the COI Official at your institution determines that one or more Investigators on this project has a Financial Conflict of Interest (FCOI, as defined in the PHS regulation) related to the project, then your institution must submit all information required for submission of an FCOI report to the University of ºÚ¶´ÉçÇø's Conflict of Interest Program, by email, according to the following:

• For new awards, information on identified FCOIs must be submitted prior to execution of the subagreement;
• For disclosure of Significant Financial Interests (SFI, as defined in the PHS regulation) made during the course of an award, information on an identified FCOI must be submitted within 45 days of your institution receiving the pertinent Investigator's disclosure.

The following information is required for an FCOI report:

• Name of the Investigator with an FCOI;
• Name of the entity with which the Investigator has an FCOI;
• Nature of the financial interest (e.g., equity, consulting fee, travel reimbursement, honorarium);
• Value of the financial interest, or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value;
• A description of how the financial interest relates to the PHS-funded research and the basis for your institution's determination that the financial interest conflicts with such research; and
• A description of the key elements of your institution's management plan, including:
  • Role and principal duties of the conflicted Investigator in the research project;
  • Conditions of the management plan;
  • How the management plan is designed to safeguard objectivity in the research project;
  • Confirmation of the Investigator's agreement to the management plan;
  • How the management plan will be monitored to ensure Investigator compliance; and
  • Other information as necessary.