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Research Integrity & Compliance
Research & Innovation » Research Integrity & Compliance » Conflict of Interest in Research

PHS and NSF Subrecipient Conflict of Interest Disclosure Forms (Forms A & B)


Potential Recipient:

You are a proposed subrecipient or consultant on a proposal that the University of South Florida intends to submit for funding from the National Science Foundation (NSF) or one of the Public Health Service (PHS) or other agencies who have adopted the PHS Objectivity in Research regulation (see list of agencies). Federal regulations require us to collect certain information from you at time of proposal and during the life of the award.

Step 1: Subrecipient Authorized Organizational Official or consultant: Please complete Form A via the electronic USF Subrecipient COI Disclosure Form System (if you have not previously submitted a Form A to USF, click "Register Here" on the log-in screen). This form must be on file before the University of South Florida can submit a proposal containing your proposed subaward.

Please note: for projects subject to the PHS Objectivity in Research regulation, if your institution is a proposed subrecipient and is on the Federal Demonstration Partnership list of institutions with a PHS-compliant Conflict of Interest (COI) policy, you do NOT need to submit Form A. Per the regulation, you must report any FCOI to the University of South Florida in the timeline specified in 42 CFR Part 50. In contrast, each consultant considered to be an Investigator (anyone responsible for the design, conduct or reporting of the research) must submit Form A as a declaration of whether s/he is following his/her own institution’s compliant COI policy or the University of South Florida’s COI Policy.

Step 2: If (and only if) the Authorized Organizational Official or consultant indicates on Form A that the University of South Florida's COI Policy will be followed (because your organization does not have its own NSF or PHS-compliant COI policy), then EACH subrecipient Investigator (defined as a person responsible for the design, conduct or reporting of the research proposed under the subaward) must be listed on Form A and complete Form B, the financial disclosure form. Form A will prompt you to "Notify All" Investigators listed, which will send a system-generated email with a personalized link to Form B to each Investigator. If you are a consultant and you are not affiliated with an institution that has a NSF or PHS-compliant COI policy, then you must list yourself as an Investigator on Form A and complete Form B, as well. As part of Form B, each Investigator must certify that they have completed USF's Financial Conflict of Interest Training for Subrecipients. Training must be repeated at least every three years.

Step 3: For projects subject to the PHS Objectivity in Research Regulation, if the Authorized Organizational Official indicates that your institution's COI policy will be followed, and if the COI Official at your institution determines that one or more Investigators on this project has a Financial Conflict of Interest (FCOI, as defined in the PHS regulation) related to the project, then your institution must submit all information required for submission of an FCOI report to the University of South Florida's Conflict of Interest Program, at COI-Research@usf.edu, according to the following:

  • For new awards, information on identified FCOIs must be submitted prior to execution of the subagreement;
  • For disclosure of Significant Financial Interests (SFI, as defined in the PHS regulation) made during the course of an award, information on an identified FCOI must be submitted within 45 days of your institution receiving the pertinent Investigator's disclosure.

The following information is required for an FCOI report:

  • Name of the Investigator with an FCOI;
  • Name of the entity with which the Investigator has an FCOI;
  • Nature of the financial interest (e.g., equity, consulting fee, travel reimbursement, honorarium);
  • Value of the financial interest, or a statement that the interest is one whose value cannot be readily determined through reference to public prices or other reasonable measures of fair market value;
  • A description of how the financial interest relates to the PHS-funded research and the basis for your institution's determination that the financial interest conflicts with such research; and
  • A description of the key elements of your institution's management plan, including:
  • Role and principal duties of the conflicted Investigator in the research project;
  • Conditions of the management plan;
  • How the management plan is designed to safeguard objectivity in the research project;
  • Confirmation of the Investigator's agreement to the management plan;
  • How the management plan will be monitored to ensure Investigator compliance; and
  • Other information as necessary.

See further information regarding the PHS regulations PDF

Proceed to Form A USF Subrecipient COI Disclosure Form System.

If you have not previously submitted a Form A to USF, click "Register Here" on the log-in screen.

Please contact the COI Program at 813-974-5638 or coi-research@usf.edu with any questions.

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