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Re: NIH revised FCOI reg - existing subawards Lynette Arias 24 Jul 2012 17:41 EST

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According to the NIH COI FACs (see below) it depends on how the institution=
 is implementing the change.  If it is effective as of Today, then the suba=
wards will need revised to bring them into compliance with the new regulati=
ons.  But you are allowed to just incorporate the changes into any new/rene=
wal agreement if that is how the institution decides to implement the chang=

Is the 2011 revised regulation retroactive? (Institution)
No.  The revised regulation will apply to each grant or cooperative agreeme=
nt with an issue date of the Notice of Award that is subsequent to the comp=
liance dates of the final rule (including noncompeting continuations) no la=
ter than August 24, 2012 and immediately upon making its Financial Conflict=
 of Interest policy publicly accessible.  Through their policies, however, =
Institutions may choose to apply the revised regulations to all active PHS =
awards.  For example, Institutions may choose, in their Financial Conflict =
of Interest policy, to implement the regulation on a single date for all PH=
S-funded awards rather than implementing the regulation sequentially on the=
 specific award date of each individual project.

Rene Hearns, PhD (cand), MPA, CRA
Director, Grants and Sponsored Programs
Edinboro University of Pennsylvania

Secretary, Northeast Section, SRA International
President, Allegheny Chapter, SRA International
Contributing Columnist, The Pulse, SRA's Catalyst

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.or=
g] On Behalf Of Chris Thompson
Sent: Monday, July 23, 2012 3:40 PM
Subject: Re: [RESADM-L] NIH revised FCOI reg - existing subawards


This came up at the NCURA PRA meeting last week in a session and the consen=
sus was that people weren't going to modify the terms of awards until the n=

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