A faculty member of ours has approached the Sponsored Programs Office
with an opportunity to do some work under a sub-contract to a Federal
grant held by a major research institution.  In the course of our
conversations, it was disclosed that the PI on the prime award was an
immediate family member of our PI.  This activity falls under the
Federal conflict of interest (COI) regulations as nepotism.

Knowing about this COI requires us to manage it.  While managing it
internally is pretty straight forward, I am looking for guidance on
disclosing it to the prime institution.  Is it our responsibility to
disclose it to them?  What type of disclosure might be appropriate?
Verbal or written.  Should the disclosure be made at a high level within
the prime institution or at lower departmental levels (where the PI in
question is the manager) or both?

Responses can be posted to the listserv or directly to me at
xxxxxx@newpaltz.edu

Patrick C. Ryan
Assistant Director for Grant Services
Office of Sponsored Programs, HAB 805
SUNY New Paltz
75 So. Manheim Boulevard
New Paltz, NY 12561
(845) 257-3282
(845) 257-3284 - FAX

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