cc7a03e5_est_in_Research_Change_Summary__1995_Regulations
[Topic] Subrecipient Institutions/Investigators and Reporting of identified FCOIs [2011 Final Rule] Incorporate as part of a written agreement terms that establish whether the FCOI policy of the awardee Institution or that of the subrecipient will apply to subrecipient Investigators and include time periods to meet disclosure and/or FCOI reporting requirements Subrecipient Institutions who rely on their FCOI policy must report identified FCOIs to the awardee Institution in sufficient time to allow the awardee Institution to report the FCOI to the PHS Awarding Component (e.g., NIH through the eRA Commons FCOI Module) to meet reporting obligations. [1995 Regulations] 
Institutions must take reasonable steps to ensure that Investigators working for subs comply with the regs by requiring those Investigators to comply with the Institution's policy or by requiring the entities to provide assurances to the Institution that will enable the Institution to comply with the regs
Conflict of Interest in Research Change Summary
1995 Regulations