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.