COIR review Process

If the UIRIS record includes a Funding Source that has a Conflict of Interest in Research Policy.

• COIR reviews Subrecipient Conflict of Interest Questionnaire – Form B.
  • Reviews project purpose to determine if COI policy of the Funding Source applies to the Subrecipient project.
  • If there is not an applicable COI policy:
    • COIR notifies DSP that no further action is required, if awarded, the outgoing subaward is ok to send.
  • If there is an applicable COI policy:
    • If A. is checked, COIR verifies subrecipient’s policy complies with the applicable federal regulation on financial conflict of interest, 42 CFR Part 50 for the Sponsor.
    • If B. is checked, COIR sends Financial Interest Disclosure Form(s) to the Subrecipient Key Personnel individual(s) to complete.

COIR Approvals

• COIR notifies DSP when the Subrecipient is approved for compliance with the applicable conflict of interest regulation.
• If the subaward is a multiple year project COIR will contact the subrecipient to ask if there are any changes to their disclosure information.

After the Subaward is Issued/Approved

• If the subaward is a multiple year project COIR will contact the subrecipient to ask if there are any changes to their disclosure information.

Resources:

University of Iowa Conflict of Interest in Research External Regulations and Policies: https://coi.research.uiowa.edu/about/regulations-and-policies

FDP COI Clearinghouse: https://thefdp.org/fcoi-compliant-entities/

FDP Expanded Clearinghouse:  https://fdpclearinghouse.org/