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.