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.