Then the following FAQ from the NIH COI page (http://grants.nih.gov/grants/policy/coifaq.htm) seems to contradict. What am I missing?

Does this regulation apply to all grants/research contracts awarded by the NIH?
No. This regulation does not apply to Phase I Small Business Innovation Research (SBIR) or Small Business Technology Transfer (STTR) program applications or awards.

The regulation also does not apply to training and fellowship awards funded under the “T” and “F” award mechanisms and to Research Construction Programs funded under C06 and UC6 award mechanisms.

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of J. Michael Slocum
Sent: Tuesday, October 18, 2011 2:10 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Serving as PI on both prime award and subaward?

No, because the conflict of interest rules are essentially the same. Again, I hope someone else has the cite on the tip of their cursor, but if need be, I can find it sometime in the next few days.

On Tue, Oct 18, 2011 at 2:45 PM, Lingle, Gary <xxxxxx@tmhs.org> wrote:

Would the answer be different if the applicant were a small business submitting under NIH’s STTR program?

Gary W. Lingle, CPA

Director, Grants and Contracts

The Methodist Hospital Research Institute

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Downey, Kaaren
Sent: Monday, October 17, 2011 5:35 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Serving as PI on both prime award and subaward?

Laurie,

At my prior institution we occasionally had investigators wanting that type of arrangement. We didn’t allow it, that completely throws off the checks and balances. You have Dr. X as the prime PI approving his own expenditures as the subrecipient. The consensus was it threw up a huge red flag to auditors

Kaaren

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From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Taylor, Laurie
Sent: Monday, October 17, 2011 4:45 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Serving as PI on both prime award and subaward?

Dear Colleagues—

We are a private, non-profit entity that regularly initiates subawards to and/or receives subawards from a university. Some of our researchers have joint appointments at our institution as well as the university. One of our researchers is putting together a proposal and wants to serve as the PI on both the prime award (which would come to us) and the subaward (which would go to the university). I was wondering if any of your institutions have a policy about this or have experience with this type of arrangement on a grant proposal.

Thanks in advance!

Laurie Taylor

******************************

Dr. Laurie A. Taylor