Guidance: Subrecipient or Contractor Financial Conflicts of Interest Disclosure

Subrecipient Organizations/Institutions

  1. If the project is for Public Health Service (PHS) or other federal programs and sponsors that have adopted PHS FCOI rules, refer to the Subrecipient Letter of Intent. If, per the Subrecipient Letter of Intent, the subrecipient organization:
    • Has implemented a written policy regarding financial conflicts of interest that complies with 45 CFR 50, Subpart F, and/or 45 CFR 94, the subrecipient’s personnel must follow their organization’s policy.
    • Has not implemented a PHS-compliant FCOI policy and procedures and instead agrees to follow ECU’s COI policy and procedures, the lead PI of the subrecipient organization must submit the FCOI disclosure to ECU’s lead PI.  [Only the lead PI of the subrecipient organization needs to submit this disclosure.]
  2. If the project is for NSF or other federal programs that have adopted NSF COI rules, refer to the Subrecipient Letter of Intent. If, per the Subrecipient Letter of Intent, the subrecipient organization:
    • Has implemented a written policy regarding financial conflicts of interest that complies with NSF’s Proposal Award Policies & Procedures Guide, Part II, Chapter IX – Grantee Standards, the subrecipient’s personnel must follow their organization’s policy.
    • Has not implemented a NSF-compliant COI policy and procedures and instead agrees to follow ECU’s COI policy and procedures, the lead PI of the subrecipient organization must submit the FCOI disclosure to ECU’s lead PI.  [Only the lead PI of the subrecipient organization needs to submit this disclosure.]
  3. If the project is for any other sponsor, no action is required.

Contractors

  1. The individual contractor must submit the FCOI disclosure to ECU’s lead PI if the project is for either of the following:
    • Public Health Service (PHS) or other federal programs and sponsors that have adopted PHS FCOI rules, or
    • NSF or other federal programs that have adopted NSF COI rules
  2. For any other sponsor, no action is required.

Questions and Issues

For questions and issues regarding completion of the Subrecipient or Contractor FCOI Disclosure, email us at coi.oric@ecu.edu.  Please include ECU’s Proposal Number which is in the YY-NNNN format.