New FCOI requirements:
Impacts to grants and contracts
How do the new FCOI requirements impact my proposal submission,
getting my budget number, and getting a subaward issued?
Presented by: OSP
August 9th, 2012
MRAM
Time of Proposal


PI determines who rises to level of
“Investigator”.
If Investigators have SFI, they must
disclose it via the Financial Disclosure
System (FIDS.)
What does OSP check?
OSP will submit the proposal to PHS agency
once each:
- role is indicated to be “Investigator” or not;
- Investigator has indicated whether he/she has SFI; and
- Investigator has disclosed.
Snapshot of eGC1 Personnel page
If this is not done at proposal stage, the proposal runs the risk of not getting
submitted in a timely manner.
Just In Time

No specific sponsor-driven JIT requirements for FCOI. As best
practice, PI/dept. should:

Remind all Investigators to take FCOI training.

Confirm with proposed subrecipients that they have an FCOI policy in
place (if PHS funding).

If they do not, suggest the FDP FCOI example policy for adoption by the
subrecipient:
http://sites.nationalacademies.org/PGA/fdp/PGA_061001
As we currently do, OSP will notify Office of Research to begin review of
disclosed SFI upon JIT notification.
Time of Award

PHS funding:




All Investigators must have taken FCOI training.
All Investigators must have disclosed SFI.
All SFI rising to level of FCOI must have a
management plan in place.
Non-PHS funding:


All Investigators must have disclosed.
All FCOI must be managed.
What does OSP do?

Check that all:




Investigators
with SFI
Disclosed
Verify:

A management plan is in place
- and -


FCOI Training Completed (PHS
only).
FCOI compliance
information available on
eGC1 Personnel page and
updated as statuses change.
We provide an FCOI report to
the Sponsor.
If these requirements are not met, OSP cannot release the funding action (FA).
What about eGC1s in “approved”
status and now awarded?


All the “bells and whistles” of the FIDs system
will not translate over to eGC1s approved prior
to 8/16/2012 until the PI and Investigators use
FIDs and “relate” the eGC1.
When an award is received for an eGC1 that was
approved prior to 8/16/2012, where SFI was
indicated, OSP will ask that the PI and
Investigators on the project use FIDs to
disclose.
Subaward Issuance

All subrecipients on a PHS-funded project must:



Confirm they have FCOI compliant policy.
Assure they will report FCOI to UW.
How do we handle at UW?

Include this language in subaward issued to the subrecipient.

If subrecipient needs to adopt a policy, FDP has issued an example
FCOI policy that can be adopted by subrecipients:
http://sites.nationalacademies.org/PGA/fdp/PGA_061001
Let subrecipients on proposed PHS project know early and often of this
requirement!
FCOI contacts



FCOI compliance and GIM 10 policy questions: Contact the Office of Research
research@uw.edu
System questions (FIDS or SAGE): Contact the Office of Research Information
Services
sagehelp@uw.edu
Proposal, award or subaward questions:

Proposals, awards: Contact your Office of Sponsored Programs representative
(Use OSP contact look-up)
http://www.washington.edu/research/index.php?page=ospContact

Subawards: Contact the OSP Subaward Team
ospsubs@uw.edu
Additional FCOI information: http://www.washington.edu/research/topics/fcoi/