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As with many other federal regulations, Northwestern must flow down Sponsored Research COI requirements to subrecipient institutions.


To ensure compliance with COI requirements, Northwestern must secure the following information prior to proposal submission:

Please use the Subrecipient COI Decision Matrix Tool  as a quick reference for subrecipient COI compliance at proposal submission.

At the proposal stage for applicable sponsors subject to COI requirements, if required by the sponsor*, the subrecipient must indicate whether or not it has a COI policy that is consistent with applicable federal requirements.  OSR confirms or obtains this information through one of the following mechanisms:

  1. Confirmation that the subrecipient is listed in the Federal Demonstration Partnership (FDP) COI Clearinghouse: ; or
  2. Inclusion of language in the subrecipient Letter of Intent (LOI) in which the subrecipient institution certifies that they have a COI policy compliant with applicable federal requirements; or
  3. Completion of a Subrecipient Commitment Form in which the subrecipient institution certifies that they have a COI policy compliant with applicable federal requirements.

If, and only if, the subrecipient is not in the FDP COI Clearinghouse and is unable to certify to a COI policy compliant with applicable requirements in the LOI or Subrecipient Commitment Form, if applicable per sponsor requirements*, the Investigators from that institution will need to follow Northwestern's COI policy for the project.

To have an Investigator at an outside institution follow Northwestern's policy, they will need to be set up in eDisclosure and complete training and disclosure requirements.  To request this, please email with the following information:

*For PHS agencies and agencies that specifically adhere to PHS COI regulations, these COI requirements flow down to subrecipients: 42 C.F.R. Part 50, Subpart F and 45 C.F.R. Part 94 For NSF, these COI requirements flow down to subrecipients: the current National Science Foundation Proposal and Award Policies and Procedures Guide. For other agencies with COI requirements: COI requirements identified in sponsor solicitation or project terms and condition are those that flow down to subrecipients


Any and all consultants that have the role of Investigators on Northwestern research -- if required by the applicable sponsor for the Northwestern research in which they are engaged -- must adhere to Northwestern's COI requirements, which is facilitated by being set-up as a POI following the instructions in Step #4 above.  Please see here for guidance on the definition of Investigator for COI purposes.   


When issuing a subagreements, Northwestern will flow down applicable sponsor COI requirements to subrecipients.  All applicable sponsor COI requirements must be met prior to award set-up, contract or subcontract execution, and/or expenditure of funds.