Subrecipient COI Management
Subrecipient institutions will be expected to elect in the subcontract to comply with their own Conflict of Interest (COI) policy or the COI policy of WFBMC.
If complying with their own COI policy, the subrecipient institution will provide a publicly accessible policy that complies with Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94). An institutional official will be expected to certify that its investigator(s) have disclosed their financial interests, that the subrecipient institution has made any Financial Conflicts of Interest (FCOI) information publicly accessible, that investigator(s) have a current record of completed mandatory FCOI education and that the institution will report identified FCOIs for its investigator(s) timely to allow WFBMC to report the FCOI to NIH as required by the regulation.
If complying with WFBMC policy, the subrecipient investigator(s) will comply with the Conflict of Interest Policies of Wake Forest Baptist Medical Center, will complete an outside interest disclosure and will complete mandatory training for Financial Conflicts of Interest (FCOI) in compliance with Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94).
If you have elected to follow the section in Wake Forest Baptist Medical Center's Conflict of Commitment and Conflict of Interest Policy related to PHS Funded research, please review the Education Module below and retrieve the code to document completion. Then, complete the Training Documentation form and the Outside Interest Disclosure form.
- PHS Funded Research 2012 Education Module
- Subrecipient PHS Training Documentation
- Outside Interest Disclosure
Please contact our office at 336-716-9300 if you have questions.