All subawardees on UO awards must have an enforced financial conflict of interest (FCOI) in research policy to comply with federal regulations and UO's Financial Conflict of Interest in Research (FCOI) policy. If not, they must follow UO's policy.
Under the UO's policy, subaward researchers responsible for the design, conduct, or reporting of research must:
- Complete FCOI training every 3 years
- Disclose annually all Significant Financial Interests for themselves, their spouse, and their dependent children related to their institutional responsibilities
- Update their disclosure within 30 days of acquiring or changing a Significant Financial Interest
- Department of Energy subawardees have 15 days to update their disclosure instead of 30, under 2 CFR Part 200 Subpart C.
Learn What Activities & Financial Interests Must Be Disclosed
Training and Declaration Forms
Each subaward researcher responsible for the design, conduct, or reporting of the research must complete the training and submit a conflict of interest disclosure using the link below.
Disclosures must be completed prior to proposal submission.
Most researchers complete the training and forms in 20 minutes, though it may take up to 1 hour depending on the number of Significant Financial Interests an employee has.
If a proposal is selected for funding, the Conflict of Interest Office will review the disclosure against the funded project for any actual or potential conflicts of interest. If they identify a conflict, the researcher will receive a management plan.
Complete Subrecipient Training and Conflict of Interest Disclosure
Department of Energy Subawards
Subawardees on DOE projects must have an enforced conflict of interest and conflict of commitment policy or they must use UO’s Financial Conflict of Interest in Research Policy and the conflict of commitment requirements of the UO’s Conflict of Interest, Conflict of Commitment, and Outside Activities Policy.
Subawardee researchers responsible for the design, conduct, or reporting of the research must submit the above training and conflict of interest disclosure during the proposal stage.
The UO will review each researcher’s disclosure against the sponsored project at the time of proposal. Conflicts that the UO cannot manage or any conflict with a foreign entity must be disclosed in the proposal itself.
Researchers must complete conflict of interest training every two years, and the DOE will accept research security training that addresses conflicts of interest and commitment. Researchers already complete research security training annually, which serves as a refresher course to meet the DOE requirements. Researchers must still complete required financial conflict of interest in research training every three years under the UO’s Financial Conflict of Interest in Research Policy.