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University of Colorado Denver

Office of Grants and Contracts

Conflict Of Interest (COI)



The University of Colorado Denver, Office of Grants and Contracts may not submit proposals to NIH, other Public Health Service agencies, or other sponsors which follow the PHS Conflict of Interest (COI) policy if the budgets include key or senior personnel who have not filed a COI Disclosure with the COI Office.
Print the document:  PHS/NIH Rules on Conflict of Interest
All proposals will be reviewed in PreAward following normal procedures. At the time of PreAward review, if it is determined the proposal budget includes key personnel who have not filed a COI Disclosure or updated a COI Disclosure within the UCD normal time frame, the proposal will be returned to the PI/administrative contact requesting the disclosure be filed with the UCD COI Office prior to the submission deadline.
Key/ senior personnel  include the Project Director/Principal Investigator and any other person who is responsible for the design, conduct and reporting of basic, animal or clinical research, this includes PRAs, or anyone who obtains informed consents, those who determine eligibility, and those who review data or conduct data analysis.
Don’t put your proposals at risk and wait until proposal submission deadlines to file COI Disclosures – be sure COI Disclosures are filed now and be sure they are updated on or as soon as possible after August 24th, 2012.
Federal regulations prohibit the Office of Grants and Contracts – UCD from submitting proposals that include key/senior personnel in proposal budgets who have not filed or update their COI.


What about subcontracts?

Print the document:  PHS/NIH Rules for Subrecipients
If a subcontracted organization has a COI policy and process, UCD will rely on that organization’s policy to satisfy this regulatory process. Each subcontract will include UCD’s requirements of the organization to fulfill the COI responsibilities.
If a subcontracted organization does not have a COI policy and process, UCD will require key personnel from the subcontracted organization to file a COI disclosure through the UCD Conflict of Interest Office. This process will be a requirement included in the subcontract.                                                                                                                            

What is defined as a financial Conflict of Interest?
What are the penalties if I fail to make the appropriate disclosures?
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