Revised PHS FCOI Regulations &
Subrecipients
IN RESPONSE TO REVISED PHS
REGULATIONS, UCI SPONSORED PROJECTS
ADMINISTRATION (SPA) HAS:
REVISED SUBRECIPIENT COMMITMENT FORM
•
•
CREATED SUBRECIPIENT FCOI ADDENDUM FORM
•
CHANGED THE PROCEDURES RELATED TO
COLLECTION OF DISCLOSURES FROM
SUBRECIPIENTS
Subrecipient Commitment Form
 Subrecipient Commitment Form was introduced to help:

Expedite the process of setting up subawards.

Designed to help subrecipients understand, at the proposal stage, what will be required of them by
UCI should an award be made.

Includes compliance with federal regulations such as those governing research with human or animal
subjects, conflict of interest, and OMB Circular A-133.
 Subrecipient Commitment Form is required:

for all proposals that include subawards and after-the-fact subaward proposal submissions.

at the proposal stage as part of the proposal package submitted to the Sponsored Projects
Officers for review.
Revised PHS FCOI Regulations
 Changes reflected in the revised PHS regulations include the
following:

Lower disclosure thresholds – $5,000 for publicly traded entities and $0 for equity
interests in non-publicly traded entities;

Investigator disclosure regarding their Significant Financial Interests (SFI) related to
their institutional responsibilities – not just those related to the specific research project
in question;

Disclosure of all sponsored and reimbursed travel – reimbursements or travel sponsored
by educational and governmental institutions are exempted;

Investigators must disclose new SFIs (including sponsored or reimbursed travel) within
thirty (30) days of discovering or acquiring a new SFI; and

Mandatory Investigator training regarding the PHS regulations and UCI’s policy prior to
engaging in the funded research.
Revised PHS FCOI Regulations & Subrecipient Commitment
Form

Subrecipient Commitment Form has been revised. This new form is mandatory for use effective 09/06/2012.

Revised form will allow Subrecipients under awards subject to these regulations declare whether they: a)
already have a Conflict of Interest (COI) policy that complies with the new PHS regulations; or b) they will
follow UCI’s Conflict of Interest policy.

Subrecipients that have a policy that complies with the PHS FCOI regulations will not have any other
requirements related to this section. However, those subrecipients that need to follow UCI’s COI Policy will
need to complete form 800SR at the time of submitting their proposal package to UCI.

The new PHS regulations also apply to awards received August 24th and thereafter. As a result, existing
subrecipients under PHS funding or subrecipients that are subsequently added to funded PHS awards will be
required to complete the Subrecipient FCOI Addendum.

Please note that we will not be able to submit PHS (including agencies that follow PHS regs) and/or NSF
proposals that include subrecipients from which we have not received the completed Subrecipient
Commitment Form and other requirements of Section 8 of Subrecipient Commitment Form. Additionally,
failure to provide a completed PHS FCOI addendum and any required form 800SR’s will delay processing of
subawards.
Questions?
Please contact Soheil Jadali at jadalis@uci.edu or 949-824-9015.