One
more note to call your attention to additional sponsors having adopted the new
PHS FCOI regulations:
American
Lung Association (ALA)
Lupus
Foundation of America (LFA)
Juvenile
Diabetes Research Foundation (JDRF)
ALA,
LFA, and JDRF are listed on the revised Investigator Form.
As the form will be updated when additional organizations adopt COI policies, please
be sure to visit the OSPA Forms page
to retrieve the latest version rather than referring back to a local copy.
The
following organizations have adopted the 2011 Revised Federal
Regulation on Financial Conflict of Interest (FCOI), effective August 24,
2012:
Alliance
for Lupus Research
American
Cancer Society
American
Heart Association
Arthritis
Foundation
Susan
G. Komen for the Cure
Note
that because these organizations have adopted the PHS FCOI rule in full, the UM and MU COI polices and OSPA procedures related to PHS FCOI
(including the PHS Investigator Form*) apply without exception. Proposals
will not be submitted to these organizations before confirmation that each
Investigator has a current Outside Interest Disclosure Form on file.
*Please note: It is possible that additional funding agencies or sponsors may require the University of Missouri to ensure that PHS rules are followed. If so, completion of this form will be required for submission to those sponsors as well.
OSPA
is planning a Certificate Series FCOI Open Forum Session for the fall to
review our first few months under the new rule. Please watch for more
information coming soon and plan to attend if your schedule allows. In the
meantime, please do not hesitate to contact me or any member of OSPA as
questions arise.
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.