While I agree on erring on the side of caution and following the policy for all sponsored programs, I do think that the question of the applicability of the FCOI policy in regards to non-research activities is a bit of a gray area. I’m not very familiar with ACF grants except insofar as I am a Head Start alumnus, but looking on their website, with the exception of OPRE, all the other funding announcements seem to be for the provision of services unrelated to generalizable knowledge. I would think that most shelters and Head Start providers would be blissfully ignorant of 42 CFR 50.

Jessica Ruth Moise

Grants and Contracts Officer

Senior Associate Dean for Sponsored Programs

Icahn School of Medicine at Mount Sinai

(formerly Mount Sinai School of Medicine)

(212) 824-8300

(212) 241-3294 (fax)

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Davis, Kelley
Sent: Thursday, January 23, 2020 8:54 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] [EXT] [RESADM-L] Non-PHS Agencies that follow PHS FCOI Policy

USE CAUTION: External Message.

Good morning,

PHS regulations for COI were in place prior to 2007 (1995), just not the regulations we are following now which were implemented in 2011 (lower $ threshold, equity changes, etc) . I’m assuming that you didn’t see anything in your proposal guidelines? As of 2017, here are the list of PHS agencies and ACF is absent.

http://thefdp.org/default/fcoi-clearinghouse/fcoi-agencies/

We use the updated PHS regulation-level standard for all projects, so it’s a bit easier, but in your case I would err on the side of PHS compliance as it’s an DHHS agency. They stopped maintaining the list of entities outside of PHS which use PHS regs a little while ago. Is there a CFDA number associated with your particular guidelines? That’s a clue as well.

Thanks,

Kelley

Kelley Davis

Conflict of Interest Administrator/Policy Analyst

436 Bowman Hall

University of Kentucky

Lexington, KY 40506

859-257-0579

xxxxxx@uky.edu

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Colleen Vogler
Sent: Wednesday, January 22, 2020 6:26 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] [EXT] [RESADM-L] Non-PHS Agencies that follow PHS FCOI Policy

Thanks, Veronica and Rachel. The latest version I've found of the DHHS Grants Policy Statement is dated January 1, 2007 which is before PHS FCOI Regulations were required, I believe.

Colleen

Colleen L. Vogler

Senior Project Representative

Direct: 734-647-2179 | xxxxxx@umich.edu

Administrative Support Staff: Dawn Curry | Direct: 734-764-7246 | xxxxxx@umich.edu

Office Hours: I am in the office Monday - Friday 9:30 am to 6:30 pm

University of Michigan | Office of Research and Sponsored Projects (ORSP)

3003 S. State Street | 1044 Wolverine Tower | Ann Arbor, MI 48109-1274

For U-M Personnel: Help us deliver quality service by providing a PAF, AWDID, UFA, or P/G number and the PI’s name whenever you contact ORSP. Up-to-date project status information is available in eRPM.

On Wed, Jan 22, 2020 at 6:15 PM Taylor, Veronica <xxxxxx@uky.edu> wrote:

Based on my reading of the websites, ACF is not a PHS agency. They are an HHS agency, but not one of the 8 PHS designated agencies: https://www.hhs.gov/about/agencies/hhs-agencies-and-offices/index.html.

However, the ACF website says they use the HHS Grants Policy Statement for their policy guide for discretionary/competitive grants, and the HHS GPS requires compliance with the PHS FCOI regulations: https://www.acf.hhs.gov/discretionary-post-award-requirements.

Veronica L. Taylor, MPA, CRA

Senior Research Administrator Lead

Office of Sponsored Projects Administration

University of Kentucky Research Foundation

208 Kinkead Hall

Lexington, KY 40506-0057

Phone: 859-257-4526

Fax: 859-323-1060

xxxxxx@uky.edu

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Morton, Jessica
Sent: Wednesday, January 22, 2020 5:09 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] [EXT] [RESADM-L] Non-PHS Agencies that follow PHS FCOI Policy

ACF is a PHS agency.

https://vpr.harvard.edu/files/ovpr-test/files/agencies_and_organizations_following_the_phs_fcoi_regulations.pdf

Jessica Morton, MPA

Senior Research Analyst

University of North Texas

College of Education

Matthews Hall 117-V

(: (940) 369-7840 *: xxxxxx@unt.edu

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Colleen Vogler
Sent: Wednesday, January 22, 2020 3:51 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [EXT] [RESADM-L] Non-PHS Agencies that follow PHS FCOI Policy

Does anyone know if ACF (Administration for Children and Families) requires compliance with PHS FCOI Regulations?

I don't believe they are a PHS agency and I can't find anything on their or DHHS websites.

Thanks, Colleen

Colleen L. Vogler

Senior Project Representative

Direct: 734-647-2179 | xxxxxx@umich.edu

Administrative Support Staff: Dawn Curry | Direct: 734-764-7246 | xxxxxx@umich.edu

Office Hours: I am in the office Monday - Friday 9:30 am to 6:30 pm

University of Michigan | Office of Research and Sponsored Projects (ORSP)

3003 S. State Street | 1044 Wolverine Tower | Ann Arbor, MI 48109-1274

For U-M Personnel: Help us deliver quality service by providing a PAF, AWDID, UFA, or P/G number and the PI’s name whenever you contact ORSP. Up-to-date project status information is available in eRPM.

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