Jump to Navigation ▼


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 PDF as a quick reference for subrecipient COI compliance at proposal submission.

  1. If department administrators/OSR verify that a subrecipient institution is listed in the FDP COI Clearinghouse, no further action is needed - the subrecipient institution will follow their own COI policy and procedures that they have certified comply with 42 CFR Part 50 Subpart F/45 CFR Part 94 to cover subrecipient investigators.  Click here to access FDP COI Clearinghouse.

  2. If an institution is NOT in the FDP COI Clearinghouse, department administrators should work with OSR to ensure that language is included in the subrecipient's LOI (letter of intent) that states that the institution has a COI policy that adheres to 42 CFR Part 50 Subpart F/45 CFR Part 94, OR facilitate the subrecipient’s completion of the OSR Subrecipient Commitment Form - PHS flow-down Word.

  3. If the OSR Subrecipient Commitment Form is used, as the form indicates, subrecipient institutions must certify that they:

    1. Have a COI policy that adheres to 42 CFR Part 50 Subpart F/45 CFR Part 94; OR

    2. Agree to abide by Northwestern’s COI policy.
  4. IF – and only IF – a subrecipient institution selects option (b) above (i.e., they do not have a COI policy and agree to abide by Northwestern’s COI policy), department administrators should proceed with the following steps:



Any and all consultants that are listed as Investigators on research projects subject to Northwestern’s COI requirements must adhere to all steps in #4 above.


Should a proposal be funded for which a subrecipient investigator and/or a consultant has agreed to adhere to Northwestern’s COI policy, a profile will be created for the individual as “POI” (person outside the institution) in eDisclosure at Just-in-Time (JIT) or as soon as notification of funding is received. This will allow the individual to complete a COI disclosure in the eDisclosure system. Any positive COI disclosures will be reviewed, COI determinations made, and any COIs related to the research managed, reduced, or eliminated prior to execution of the applicable subrecipient or consultant agreement and release of funding.  

NUCOI can establish an account for a POI in eDisclosure.  To request that a POI be set up in eDisclosure, research administrators should send the following information to nucoi@northwestern:

  • Subrecipient or consultant Investigator name
  • Email address
  • Name of subrecipient institution (if applicable)
  • InfoEd project #