OSPA SPPG Addition: Financial Conflict of Interest in PHS-Funded Research

The 2011 Revised Federal Regulation on Financial Conflict of Interest (FCOI) goes into effect today, Friday, August 24, 2012. Consistent with UM and MU policy changes, the OSPA Sponsored Programs Procedure Guide (SPPG) is updated to include a topic entitled Financial Conflict of Interest in PHS-Funded Research. The procedure outlines new mandatory requirements at proposal (before submission) and at award (before expenditure of funds) for PHS Investigators, including subrecipients. Please note also that a new Subrecipient Commitment Form, referenced in the FCOI procedure, is posted to the OSPA Forms page.

Thank you to so many of you for proactively turning your attention to these important changes and for your assistance and patience leading up to today. As PHS proposal submission deadlines approach, awards are received, and changes occur during the period of performance, we are here to help you. Please call me, your SGCA or Sr. Accountant, or any other member of OSPA anytime.

HHS and PHS Operating Divisions

Considering that both the HHS Salary Cap and PHS Financial Conflict of Interest (FCOI) Policy are with us for the foreseeable future, please find below for reference the lists of operating divisions that comprise each agency. 

The US Department of Health and Human Services Organizational Chart (screenshot below) illustrates that there are just a few extra HHS operating divisions that are not PHS. 

OSPA Draft Procedures on Conflict of Interest in Research

Attached please find new draft OSPA procedures pertaining to the 2011 Revised Federal Regulation on Financial Conflict of Interest (FCOI). Consistent with UM and MU policy changes, final OSPA procedures will be posted and go into effect this Friday, August 24, 2012. Please note that there are new mandatory requirements at proposal (before submission) and at award (before expenditure of funds) for PHS Investigators, including subrecipients.

Please review and reply with questions, concerns, or any other feedback by Wednesday, August 22. Similar to the uncharted territory of ARRA reporting, we expect to make adjustments as we go in the early days and months under the new regulation. I look forward to hearing from you at any point along the way. 

Attachment 1 

Attachment 2 

RE: Federal Conflict of Interest Rule Changes – OSPA procedures coming soon!

Please expect new OSPA procedures related to the revised PHS COI regulations in the next few days for a short review period before we finalize and implement for the August 24, 2012, effective date. Should you have questions in the meantime, please don’t hesitate to call me. 

                                                                                                                                                      

June 13, 2012

Research Community,

The Public Health and Services (PHS), which includes the National Institutes of Health (NIH) and the Food and Drug Administration (FDA), has revised the regulations that govern Conflict of Interest (COI).  The regulation has new requirements for both MU as a PHS-funded Institution and the Investigators who work on those projects.  Implementation of these new processes will begin on August 24, 2012.  The COI Office is taking the lead on ensuring these regulations are met. 

We will be giving a detailed presentation about these changes for all Investigators and Staff who are interested on June 26, 2012 from 1-3pm in the Monsanto Auditorium in the Bond Life Sciences Center. We encourage all to attend, especially those who currently have PHS funding.