All subrecipients on UO awards must have an enforced financial conflict of interest (FCOI) in research policy to comply with federal regulations and UO policy. If not, they must follow UO's FCOI Policy.
Under the UO's policy, subrecipient personnel 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 disclosures within 30 days of acquiring or changing a Significant Financial Interest
Learn What Activities & Financial Interests Must Be Disclosed
The Department of Energy requires all research participants—not just PIs or senior/key personnel —to complete a financial conflict of interest disclosure and training. This requirement includes graduate and undergraduate students listed on the budget. Staff in the Conflict of Interest Office will contact PIs of DOE-funded projects that have this broader requirement.
Training and Declaration Forms
Each employee 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.
Most employees 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.
Complete Subrecipient Training and Conflict of Interest Disclosure
Subawardees on Department of Energy Grants
Under awards subject to the Department of Energy’s Interim COI Policy, anyone who “participates in the purpose, design, conduct, or reporting of a project funded by DOE” must complete COI training, submit an annual financial conflict of interest disclosure, and update it within 30 days of any change or new interest. This requirement extends beyond PIs, co-PIs, and senior/key personnel who typically complete COI training and disclosures.
DOE subaward PIs may receive a request from the Conflict of Interest Office to provide names and contact information of postdocs, graduate or undergraduate students, or others whose work will be charged to the sponsored award and who would not usually submit disclosures