Subrecipient Process Changes due to New Federal COI Policy

New Federal regulations on  Financial Conflicts of Interest (COI) announced earlier this summer become effective August 24, 2012. In addition to impacting UW-Madison investigators, the new COI policy also affects our subrecipients on PHS-funded sponsored programs.

Subrecipient Business Process Changes

RSP Notice 2013-1, issued Aug 14, 2012, introduces a new business process related to proposed and current PHS subrecipients. This new process emphasizes obtaining certain information about Significant Financial Interests from subrecipients at the proposal stage.

As of August 24, prior to proposal submission the University must obtain information from each proposed subrecipient about whether the subrecipient:

(1) has their own PHS-compliant financial conflict of interest policy


(2) does not have a policy and will agree to be subject to UW-Madison’s policy on financial conflict of interest.

The University currently has about 600 unique subrecipients, and we can anticipate that some of the smaller entities, small business, and foreign entities may need to use our policy. Consequently, guidance has been developed, which is included in RSP Notice 2013-1.

For More Information

Learn about how new COI regulations will impact you by attending an upcoming town hall meeting:

Grants Management & the New Federal COI Regulations

  • Tues, Aug 21,2012, 9:00-11:00am
    Health Sciences Learning Center (750 Highland Ave) , Rm 1345
  • Thurs, Aug 23,2012, 9:00-11:00am
    Biotech Center (425 Henry Mall) , Rm 1111

For general information on UW-Madison’s Conflict of Interest policies and procedures, visit the Graduate School’s Conflict of Interest page at