New PHS FCOI Regulations & Subrecipients

Dear Colleagues:

In response to revised Public Health Service (PHS) regulations regarding
financial conflict of interest (FCOI) that went into effect on August
24, 2012 (please see, attached, the previous email notification from
Bruce Morgan), we have made changes to our Subrecipient Commitment Form .
This new form is mandatory for use effective 09/06/2012. Specifically,
Section 8 of the Subrecipient Commitment Form, has been revised so that
subrecipients included in proposals to PHS Sponsors or Sponsors
following the PHS conflict of interest regulations may indicate whether:

a) Subrecipient already has a Conflict of Interest (COI) policy that
complies with the new PHS regulations; or

b) Subrecipient will follow UCI’s Conflict of Interest policy.

Subrecipients that have a policy that complies with the PHS FCOI
regulations will not have any other requirements related to this
section. However, those subrecipients that need to follow UCI’s COI
Policy will need to complete form 800SR
orm-800SR.doc> at the time of submitting their proposal package to UCI.

The new PHS regulations also apply to awards received August 24th or
thereafter. As a result, existing subrecipients under PHS funding or
subrecipients that are subsequently added to funded PHS awards will be
required to complete the Subrecipient FCOI Addendum Form . This
form provides a way for those subrecipients to provide information on
whether or not they have a policy that complies with the new PHS COI
regulations. Subrecipients that do not have a policy and need to follow
UCI’s COI Policy are required to complete and submit form 800SR to UCI.

Conflict of Interest requirements for Sponsors following NSF regulations
will continue in accordance with existing NSF regulations.

Please note that we will not be able to submit PHS and/or NSF proposals
that include subrecipients from which we have not received the completed
Subrecipient Commitment Form and other requirements of Section 8 of
Subrecipient Commitment Form. Additionally, failure to provide a
completed PHS FCOI addendum and any required form 800SR’s will delay
processing of subawards.

The above mentioned forms are available on the SPA website ( as well as OR’s Applications and
Forms webpage (

For questions please contact Soheil Jadali at or (949)

OR-SPA mailing list

default iconNew COI Disclosures Requirement.pdf

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