Any thoughts on the still (to me) unclear definition of “investigator”?
“…regardless of title or position, who is
responsible for the design, conduct, or reporting of research…
which may include, for example, collaborators or consultants”
How deep or broad does responsibility go?
KEY persons are those who “contribute to the scientific development or execution of a project in a substantive, measurable way” and we all know that
some PIs consider some postdocs (and senior technicians?) as key…and some do not!
Charlie
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Stroud, Suzanne
Sent: Tuesday, April 17, 2012 3:26 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NIH FCOI implementation of new reg (8/24/12)
Please see something very helpful that NIH published last Thursday. This is NIH’s updated checklist for the FCOI policy implementation. There is no mention of JIT or limiting
it only to JIT stage.
http://grants.nih.gov/grants/policy/coi/checklist_policy_dev_20120412.pdf
According to the regs via 42 CFR 50.603 it will be required that only the investigator must disclose SFI that may impact the investigator’s institutional
activities one of three options:
·
In preaward at the time of the
proposal submission or
·
in postaward annually during the period of the award
·
Or within 30 days whenever a new SFI is realized.
Don’t forget this applies to all (y)our subawardees also, so will impact pre- and post-award in how you handle contract certification. Some
suggestions have been to have a certification statement in the Letter of Intent from our subs that carries through to the post-award contract stage. Consultants can provide a certification at the proposal stage if the individual has been identified.
So whatever is decided at your institution to implement a process to adhere to the reg, it is written in the CFR that you must have a system organized enough to deliver responses
to HHS immediately:
|
“
Agrees to make FCOI and SFI information (including related Institutional reviews and determinations) available to HHS, promptly, upon request …” |
Suzy
Suzanne Stroud,
CRA, CPRA
Sr. Research Administrator, Post-award
Office of Contracts and Grants
Division of Research
713-743-9626
From: Research Administration List
[mailto:xxxxxx@lists.healthresearch.org]
On Behalf Of Cindy Fuqua
Sent: Tuesday, April 17, 2012 1:52 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] NIH FCOI implementation of new reg (8/24/12)
Dear Resadmins,
Can you please share how the FCOI-regulation required certification will be coordinated by your pre-award offices for new and competing awards? Will such certifications be triggered at Just-in-Time typically,
for example?
Many thanks!
Cindy Fuqua
Manager, Administrative Post-Award
Sponsored Research and Program Development
The Rockefeller University
1230 York Avenue, Box 82
New York, NY 10065-6399
t: 212-327-8055
f: 212-327-8400
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A link directly to helpful tips:
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