Topics Map > Research Policy and Compliance > Conflict of Interest (COI) and Outside Activities Reporting (OAR) > Individual Financial Conflict of Interest (FCOI)
Topics Map > Research Policy and Compliance > Conflict of Interest (COI) and Outside Activities Reporting (OAR) > Administrative Staff and Reviewer Resources

Sub-recipients for PHS Funded Research


A sub-recipient relationship is established when the following conditions are present: (1) PHS funding flows from or through UW–Madison to another individual or entity, (2) the sub-recipient will be conducting a portion of the PHS-funded research project, and (3) the sub-recipient is accountable to UW–Madison for programmatic outcomes and compliance matters. Accordingly, when UW-Madison is a recipient of PHS funds from an awardee institution, the Financial Conflict of Interest (FCOI) regulations apply.

If an investigator on a PHS-funded grant has or will have a sub-recipient on the funded project (e.g., subcontractors or consortium members), UW-Madison, as the awardee institution, must take reasonable steps to ensure that sub-recipient investigators comply with the federal FCOI regulations. This will be incorporated in a written agreement with the sub-recipient that establish whether UW-Madison's COI policy or the sub-recipient's policy will apply to the sub-recipient's investigators.

When Sub-recipient Investigators Comply with Sub-recipient Entity's COI Policy

If the sub-recipient's investigators comply with the sub-recipient's COI policy, the sub-recipient shall certify, as part of the sub-award agreement with UW-Madison, that its policy complies with federal regulations. The agreement will also specify time periods for the sub-recipient to report identified FCOIs to UW-Madison to allow sufficient time to provide FCOI reports to the PHS funding agency. Sub-recipients who do not have policies and procedures that comply with federal FCOI regulations can be found at the following website:

When Sub-recipient Investigators Comply with UW-Madison COI Policy

If the sub-recipient does not have a COI policy or its policy does not comply with the federal regulations, the sub-recipient must certify as part of the sub-award agreement that it will comply with UW-Madison's COI policy. The agreement will also specify time periods for the sub-recipient to submit all investigator disclosures of outside financial interests to UW-Madison to allow UW-Madison to review, potentially manage, and report to PHS about these interests.

Sub-recipient investigators who must comply with UW-Madison COI Policy are required to fulfill specific requirements at two different times: (1) before a proposal for funding is submitted to a PHS agency and (2) before any funds on a PHS away may be expended.

Before Proposal Submission - Before a proposal to a PHS agency may be submitted for funding, all investigators, including sub-recipient investigators, must complete the electronic Outside Activities Report (OAR). Sub-recipient investigators who do not have a UW-Madison NetID must apply for one online at:

At Award Setup - Before investigators on a PHS-funded project may expend PHS funds, all investigators must update their OAR (regardless of whether investigators have new or changed outside interests to disclose) and complete COI training. Sub-recipient investigators will use their UW-Madison NetID to update their OAR and complete the COI training.

Sub-recipients Following UW-Madison COI Policy

If you are a sub-recipient investigator on a Public Health Services (PHS) award AND you will be following UW-Madison's Conflict of Interest (COI) Policy, you must complete these three steps to be authorized to spend award funds:

1.        Obtain a UW NetID – In order to access the UW-Madison COI online tools and to complete steps 2 and 3 below, you will need a UW NetID. To request a UW NetID, please complete and submit the NetID request form. Once the request has been processed, you will receive an email containing information on how to activate your UW NetID.

2.        Complete UW-Madison COI Training – The University of Wisconsin's COI Policy requires all investigators to complete COI training.  This training is available at Learn@UW, a UW-Madison training program. You will need your UW NetID to access this program. The UW COI Training Course should take only 10-15 minutes to complete. For instructions on how to complete the COI Training Course, please click here Conflict of Interest Training Course

3.        File a UW-Madison Outside Activities Report – The University of Wisconsin's COI Policy also requires all investigators to file an Outside Activities Report (OAR) within 30 days of the start of spending on PHS awards. This electronic form will ask you a series of questions required by federal regulations about your outside financial interests. Please follow this link and use your UW NetID to login to the OAR online tool.

Once you have filed your OAR and completed the COI Training Course, the UW-Madison COI Program and Research and Sponsored Programs will work to complete the award setup process and authorize the expenditure of your funds. Failure to complete the above tasks in a timely manner will delay the setup of your award and your ability to expend award funds.

If you have any questions, please contact the COI Program at

Keywords:subrecipient, sub-recipient, conflict of interest, PHS, Public Health Service   Doc ID:35538
Owner:Samuel L.Group:VCRGE and Graduate School
Created:2013-12-02 16:21 CSTUpdated:2015-06-11 13:27 CST
Sites:VCRGE and Graduate School
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