Subcontractors and PHS Funding

The federal regulation on financial conflict of interest in research applies not only to UI investigators, but also to investigators at organizations proposed for subcontracting (subrecipients, subawardees, etc.), who are considered to be "key personnel" by the UI Principal Investigator, with PHS-funded research. The subrecipient organization is required to either have its own conflict of interest policy that complies with the federal regulation, or follow the University of Iowa policy.

The Federal Demonstration Partnership (FDP) has developed a directory, called the FCOI Clearinghouse, which lists organizations that have certified that they comply with the federal conflict of interest requirements.

Follow these steps as you begin the routing process for the PHS application:

Initiate a Routing Form for the proposal. In Section 6.3, enter the name of the subrecipient organization. If the organization has certified on the FDP Clearinghouse, that will be noted on the Routing Form. If the routing form states that the subrecipient is not on the FDP Clearinghouse, and you believe this is incorrect, the FDP Clearinghouse should be checked to confirm the certification. If the subrecipient is listed on the FDP Clearinghouse, mark “Yes” on the routing form and enter comments in the Comment Field.

If one or more of the subrecipients is NOT listed on the FDP Clearinghouse, complete a Form B for each unlisted organization and send it to the administrative contact at the organization. Form B allows the subrecipient organization to declare whether or not they have a compliant policy, even though they are not on the FDP Clearinghouse. The subrecipient’s administrative contact should return the completed Form B to you. If all subrecipient organizations have indicated on Form B that they have a compliant policy, attach Form B to the Routing Form.

If any subrecipient has indicated on Form B that they DO NOT have a compliant policy and will be following UI’s policy, please attach the completed Form B to the routing form before submitting for approval.

Having a subrecipient follow the UI policy means that its investigator(s) must complete a UI Financial Interest Disclosure Form and a training module before the project can be submitted to the funding agency. The COIR Office will provide the necessary documents for the subrecipient so that each investigator can complete them.  The COIR Office will email you when the documents have been returned by the subrecipient investigator(s). This confirmatory email, along with Form B, must be attached to the Routing Form prior to submission.

The important thing to remember is that this process must be completed prior to Sponsored Program’s submission of the grant application.  It is advisable that the process be started as early as possible. Please consult with the UI Principal Investigator and the Division of Sponsored Programs to determine if "key personnel" functions are being carried out at the subrecipient organization.