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PHS Conflict of Interest Regulations Terry A. May 21 Jun 1995 10:49 EST

 I was getting nervous that the extension would be delayed until after
7/1 and inquired to NSF yesterday about their intent.  My question happened
to coincide with publication; hence my alert to all as I generally do not
see items in the FR until some time after publication and felt many would
be interested as we are rapidly approaching 7/1.  My second comment about
technical changes was essentially verbatim the response from NSF.  I do not
know the details but assume they will be along the lines of the comments
provided some time ago by Jane Youngers.  The relevant parts of her note
are attached below.  I certainly would invite others (Jane?) to correct my
impression if I'm wrong, but I suppose the bottom line is that this will
make NCURA's regulatory conference in Keystone, CO more timely and
relevant.

"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..... Finally, it does not appear that PHS will address
institutional conflicts of interest at this time."

Terry A. May, Ph.D.                       Voice:    520-523-6788
 Director of Research Administration     FAX:      520-523-1075
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