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Office of Research Compliance and Assurance

Subrecipients: Financial Conflict of Interest Resource Repository

For PHS Agencies and Non-PHS Organizations Applying PHS Financial Conflict of Interest Requirements
List of PHS and Non-PHS agencies list
SOPs: Processes for Subrecipients (A Guide for USA PI’s and Grants Administrators)
Subrecipient Instruction and Forms Packet
    • “Investigator” means a project director or any other person, regardless of position or title, who is responsible for the design, conduct, or reporting or research funded by the Public Health Service (PHS), or for a proposal seeking such funding. Since title and position are not indications of who is an "Investigator" as defined by PHS, it is possible for students and postdocs to meet this definition. Senior or key personnel listed on a proposal/award may be considered an Investigator for purposes of submitting a conflict of interest disclosure form. Senior/key personnel are considered to be individuals who have the authority to make independent decisions about the direction of the research and the subsequent conclusions about the results. This does not include administrative personnel or individuals who perform routine, pre-defined, or incidental tasks related to the project.
  • Disclosure must be on file before the Office of Sponsored Programs can submit the proposal to a PHS agency or designated Non-PHS agency on or after 8/24/12
FDP Model Financial Conflict of Interest Policy and Model Disclosure Form
(for potential adoption by subrecipients not yet having their own FCOI policy)
The model policy and form listed below is intended to assist subrecipients who wish to create their own Financial Conflict of Interest policy. This model policy has been developed by members of the FDP who are familiar with PHS Financial Conflict of Interest requirements; however, subrecipients are independently responsible for conducting their own review to ensure that this model or an adapted version is compliant with PHS policy. Tools are available on the NIH web site to assist institutions with this process, including a Checklist for Policy Development at: and a FCOI tutorial at:
CITI Financial Conflict of Interest Training

PHS Conflict of Interest Regulations:
University of South Alabama Financial Conflict of Interest Policy:

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