Presented by: OSP August 9 th , 2012 MRAM

1. New FCOI requirements: Impacts to grants and contractsHow do the new FCOI requirements impact my proposal submission, getting my budget number, and getting a subaward issued? Presented by: OSP August 9th, 2012 MRAM

2. Time of Proposal • PI determines who rises to level of “Investigator”. • If Investigators have SFI, they must disclose it via the Financial Disclosure System (FIDS.)

3. What does OSP check? OSP will submit the proposal to PHS agency once each: - role is indicated to be “Investigator” or not; - Investigator has indicated whether he/she has SFI; and - Investigator has disclosed. Snapshot of eGC1 Personnel page If this is not done at proposal stage, the proposal runs the risk of not getting submitted in a timely manner.

4. Just In Time • No specific sponsor-driven JIT requirements for FCOI. As best practice, PI/dept. should: • Remind all Investigators to take FCOI training. • Confirm with proposed subrecipients that they have an FCOI policy in place (if PHS funding). • If they do not, suggest the FDP FCOI example policy for adoption by the subrecipient: http://sites.nationalacademies.org/PGA/fdp/PGA_061001 As we currently do, OSP will notify Office of Research to begin review of disclosed SFI upon JIT notification.

5. Time of Award • PHS funding: • All Investigators must have taken FCOI training. • All Investigators must have disclosed SFI. • All SFI rising to level of FCOI must have a management plan in place. • Non-PHS funding: • All Investigators must have disclosed. • All FCOI must be managed.

6. Check that all: Investigators with SFI Disclosed Verify: A management plan is in place - and - FCOI Training Completed (PHS only). We provide an FCOI report to the Sponsor. What does OSP do? FCOI compliance information available on eGC1 Personnel page and updated as statuses change. If these requirements are not met, OSP cannot release the funding action (FA).

7. What about eGC1s in “approved” status and now awarded? • All the “bells and whistles” of the FIDs system will not translate over to eGC1s approved prior to 8/16/2012 until the PI and Investigators use FIDs and “relate” the eGC1. • When an award is received for an eGC1 that was approved prior to 8/16/2012, where SFI was indicated, OSP will ask that the PI and Investigators on the project use FIDs to disclose.

8. Subaward Issuance • All subrecipients on a PHS-funded project must: • Confirm they have FCOI compliant policy. • Assure they will report FCOI to UW. • How do we handle at UW? • Include this language in subaward issued to the subrecipient. • If subrecipient needs to adopt a policy, FDP has issued an example FCOI policy that can be adopted by subrecipients: http://sites.nationalacademies.org/PGA/fdp/PGA_061001 Let subrecipients on proposed PHS project know early and often of this requirement!

9. FCOI contacts • FCOI compliance and GIM 10 policy questions: Contact the Office of Research research@uw.edu • System questions (FIDS or SAGE): Contact the Office of Research Information Services sagehelp@uw.edu • Proposal, award or subaward questions: • Proposals, awards: Contact your Office of Sponsored Programs representative (Use OSP contact look-up) http://www.washington.edu/research/index.php?page=ospContact • Subawards: Contact the OSP Subaward Team ospsubs@uw.edu Additional FCOI information: http://www.washington.edu/research/topics/fcoi/