PHS Conflict of Interest Regulations Youngers, Jane A. 22 Mar 1995 14:47 EST

In response to Len's question about PHS COI, I'll tell you what I know.
 Reliable sources tells us its somewhat unlikely that PHS will implement by
July--October 1 is more realistic.  It also appears that NSF will stick with
its June 28 effective date, but that they will be publishing revisions to
their policy shortly in the Federal Register.  Among these revisions will be
an increase from $5k to $10k in the definition of significant financial
interest.  (Hooray!  This will eliminate a lot of time consuming disclosure
reviews.)  PHS will also most likely adapt the $10k definition.  There is
also some indication that subawardees will need to certify to the prime that
they are in compliance; that disclosures will not have to be reviewed at
time of application, but when the award is about to be made the agency will
contact us to make sure everything is OK.  Both agencies appear to continue
to resist a more definitive definition of who must disclose; it's up to us
as institutions to decide.  (At  Rochester we have decided that only PI's,
Co-PI's, PD's, and Co-PD's will make disclosure.  And, yippee, yesterday our
Faculty Senate signed off on our revised policy!)   Finally, it does not
appear that PHS will address institutional conflicts of interest at this

I guess that just about downloads my brain-bank of COI info.

Jane Youngers
University of Rochester