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FCOI and Subrecipients

When the University of Houston is the primary awardee of a collaborative PHS- or NSF-funded project, it must ensure that the financial interests of all subrecipients are reviewed and eliminated or managed properly. During the proposal stage and during the negotiation of a subaward, it must be verified that all subrecipients/potential subrecipients of the funding are in compliance with Conflict of Interest regulatory requirements. Certification that the institution receiving the subaward has a compliant policy in place will be verified via the FDP FCOI Institutional Clearinghouse.  Those institutions who have not certified with FDP will be required to certify the following in writing via a Letter of Compliance, on institutional letterhead, prior to the release of funds (see FCOI Subrecipient Letter template (DOC):

  • The subrecipient Institution has a policy in place to review and manage Significant Financial Conflicts of Interest that meets regulatory requirements.
  • The subrecipient's policy applies to the subawarded portion of the research project, and
  • The subrecipient must agree that the identification of and management plan of any FCOI identified will be submitted to the awardee Institution for required reporting purposes.

If the subawardee Institution does not have a compliant FCOI program in place, the agreement must indicate that the subrecipient will follow UH FCOI policy, including the pre-award and annual submission of a Certification (and disclosure, if applicable) to the UH COIC within 30 days of the submission of the proposal.