In accordance with 42 CFR Part 50 SubPart F and 45 CFR Part 94, all investigators and key research personnel participating in the project must comply with the written policies of the contractor relating to the disclosure of Significant Financial Interests which may constitute or may be perceived to constitute a Financial Conflict of Interest affecting the design, conduct or reporting of the project.

If your Subaward/Subcontract/Consultant Agreement is being issued under a prime award from HHS, PHS, NIH or other non-federal agency that applies the PHS FCOI regulations, there must be verification that the Subrecipient/Subcontractor/Consultant has a policy that complies with the 2011 PHS FCOI regulations:  

  • Check the FDP Clearinghouse (http://sites.nationalacademies.org/PGA/fdp/PGA_070596) to see if the Subrecipient/Subcontractor/Consultant is registered as compliant; or
  • Obtain an endorsed letter or certification from the Subrecipient/Subcontractor/Consultant verifying and attesting that it has a policy that complies with the 2011 PHS FCOI regulations; or
  • Request that the Subrecipient/Subcontractor/Consultant complete this Subrecipient Financial Conflicts of Interest Certification Form (http://research.uic.edu/sponsored-programs/forms-contract-templates).

If the Subrecipient/Subcontractor/Consultant does not have a financial disclosure policy consistent with 42 CFR Part 50 SubPart F and cannot provide such certification, the investigators will be subject to the University of Illinois financial conflicts of interest policy for disclosing significant financial interests that are directly related to the subrecipient’s involvement in the project and training. 

When submitting a Subaward/Subcontract/Consultant Agreement packet for those Subrecipient/Subcontractor/Consultant Agreements issued under a prime award from HHS, PHS, NIH or other non-federal agency that applies the PHS FCOI regulations to ORS, you must include a screen shot of the FDP page or a copy of the certification form or Subrecipient/Subcontractor/Consultant  attestation letter with the package when submitting to ORS

  • Subrecipient Financial Conflicts of Interest Certification Form 
    PI or business manager should use this form at the time of proposal for HHS, PHS, NIH sponsored research or any other non-federal agency that applies the PHS FCOI regulations when there will be a sub-award.
  • FDP Clearinghouse for COI
    Federal Demonstration Partnership Clearinghouse for the PHS FCOI regulations.Business managers can check when an institution has registered with the FDP Clearing to verify if the institution attests that it has a policy that complies with the 2011 PHS FCOI regulations. If an institution is not listed, please complete the form below.
  • FDP model COI Policy for small businesses 
    If the contractor does not have a financial disclosure policy consistent with 42 CFR Part 50 SubPart F, but wants to develop a policy, guidance is available from the Federal Demonstration Project (FDP).  The FDP has created a checklist that outlines the requirements of the federal regulations.  The FDP also has a model COI Policy for small business entities to adapt.  If the entity creates its own policy, the entity could register with the FDP Clearinghouse for COI. 

Additional information may be found at: http://research.uic.edu/coi/conflict-commitment-and-interest/public-health-services-phs-disclosure-training