Subrecipients Requirements

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