COI: Sub-Recipients for PHS-Funded Research

This document provides guidance for those whose role as a sub-recipient of federal funds makes them subject to UW-Madison's Conflict of Interest Policy.

A sub-recipient relationship is established when federal funds flow through UW-Madison to another entity.  This sub-recipient will be conducting a portion of a PHS-funded research project, and is accountable to UW-Madison for compliance matters.  As such, conflict of interest requirements in place for UW-Madison investigators also apply to PHS-funded sub-recipients.

Sub-recipients must either certify that their own institution's COI policies comply with the PHS standards, or that they will comply with UW-Madison's COI policies. This certification must be included in the sub-award agreement.

Sub-recipient investigators who must comply with the UW-Madison COI Policy are required to fulfill specific requirements at proposal submission and before any federal funds may be expended. 

  • At proposal submission, all sub-recipient investigators must complete their COI training and report their outside financial interests to the UW-Madison through the same mechanisms as used by UW-Madison investigators. 
  • At award set-up, all investigators (UW-Madison and sub-recipient) must update their Outside Activities Report (OAR), even if there is no new or updated information to report.

Specific directions for sub-recipients can be found in this Graduate School's KnowledgeBase document.

Keywords:conflict interest subrecipient   Doc ID:43028
Owner:Rebecca D.Group:College of Letters & Science
Created:2014-08-20 11:02 CDTUpdated:2014-10-16 16:05 CDT
Sites:College of Letters & Science
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