I’m submitting a proposal with a subaward whose PI is considered an investigator, and the subrecipient is a small organization that doesn’t have a PHS compliant COI policy in place. How should we handle this at time of submission to be compliant?

When you add an individual to the research team and answer the question “Is this person responsible for the design, conduct or reporting?”, answer “No” for subcontractor investigators.

HMS is responsible for ensuring that any sub-recipient's institution affirms that the institution has a PHS compliant COI policy and will report any FCOIs identified to HMS in a timely manner.  HMS will be responsible for reporting it to PHS prior to any spending on subaward (or prior to commencement of new investigator participation).  If sub-recipient institution does not have a COI policy, HMS will provide a PHS compliant COI policy and related disclosure form for the sub-recipient institution to consider for adoption.  Additionally, HMS ensures that the subawardee institution adopts a PHS Compliant Policy.  ARI and SPA have incorporated language to reflect the process in subawards.