Conflict of Interest Policy Reminders for Awards and PHS Proposals

Submitting a No-cost Extension request?

Remember – the revised Emory Conflict of Interest policies that went into effect in August 2012 require annual financial interest disclosures on each award. This means that all Investigators on an award, as defined in Emory Policy 7.7, must complete an Investigator Report on Financial Interests in Research at the time of the No-Cost Extension. To expedite NCE requests, please submit the summary report from the eCOI system with the NCE request.

Have a subaward or consortium partner on your grant to a PHS agency?

Remember – all financial interest disclosures must be collected by Emory prior to proposal submission. This applies for subawards, as well. If a subaward partner has a COI policy that is compliant with the 2012 PHS policy, they can indicate to us that they have a policy and have collected the appropriate disclosures. In that case, they do not need to provide the actual disclosures to Emory. However, if a subaward partner does not have a COI policy that is compliant with the 2012 PHS policy, they must adhere to Emory’s policy. In these cases, any subaward investigators must submit a paper disclosure form to Emory prior to proposal submission.

In order to help capture this information, OSP has drafted a new consortium letter that should be used on all PHS grant submissions (including all NIH proposals). This letter can be found on the OSP website at: {Demetrice, if I send you the template, can you post and then include the link in the article}.

In addition, the paper Investigator Report on Financial Interests in Research  (for external investigators not on a subaward to an institution with a compliant policy) may be found at:

For questions on a specific proposal, subaward, or NCE request, contact your OSP analyst.


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