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:
- Department administrators should work with OSR to ensure that language is included in the subrecipient's 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 .
- If the OSR Subrecipient Commitment Form is used, as the form indicates, subrecipient institutions must certify that they:
- Have a COI policy that adheres to 42 CFR Part 50 Subpart F/45 CFR Part 94; OR
- Agree to establish a COI policy that adhere to 42 CFR Part 50 Subpart F/45 CFR Part 94; OR
- Agree to abide by Northwestern’s COI policy.
- IF – and only IF – a subrecipient institution selects option (c) 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:
- Department administrators should send the subrecipient institution Northwestern’s Subrecipient/Consultant Investigator Conflict of Interest Disclosure and Certification Form , and attach the PDF COI training document
- Each subrecipient Investigator on the proposed research project must complete the Subrecipient/Consultant Investigator Conflict of Interest Disclosure and Certification Form , which attests to review of the training document as well as solicits COI disclosure information
- The subrecipient Investigator should submit the form directly to firstname.lastname@example.org. If a subrecipient institution or investigator submits a form to the department administrator or OSR, the form should immediately be forwarded to email@example.com.
Any and all consultants that are listed as Investigators on research projects subject to Northwestern’s COI requirements must adhere to all steps in #3 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 InfoEd and FASIS 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 FASIS 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.