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NIH Financial Conflict of Interest – Action Required by 12/1/2020

November 20, 2020 / Ed Jameson / Blog Posts
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The NIH requirement for a publicly accessible Financial Conflict of Interest (FCOI) policy has been around since 2011.  As a result, Grantees were required to have this policy posted on their website.

NIH Guide Notice NOT-0D-21-002 Required Submission of Financial Conflict of Interest Policy into the eRA Commons Institution Profile (IPF)

Effective November 12, 2020, NIH-funded recipients must upload their FCOI policy to NIH via the eRA Commons Institution Profile (IPF) by December 1. 2020. 

This requirement applies to all NIH applicants and/or recipients EXCEPT Phase I SBIR and Phase I STTR applicants and/or recipients.  Please note: Fast Track SBIR/STTRs recipients are subject to the FCOI policy regulation prior to NIH’s award of the type 4 R44, U44, R42, and UT2 Phase II SBIR/STTR awards.

We assume that NIH will check to make sure grantees are complying with this new rule.  Failure may cause the NIH to delay awards, imposition of grant conditions, or other enforcement actions.

Next steps to comply with NIH

Most grantees have an FCOI policy in place, so submitting a PDF version of this document to the eRA Commons Institution Profile (IPF) Module shouldn’t require too much effort.

However, newer NIH grantees may need to create an FCOI policy.  To ensure that your policy meets NIH requirements, we suggest reviewing the “FCOI Policy Development Checklist.” 

As always, if you want to discuss your NIH grant and compliance, reach out to the government grant accounting experts at Jameson.  Fill out the form below and we’ll be in touch promptly.

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Ed Jameson, CPA, Managing Partner

I’ve been in practice for over 40 years helping our small business clients procure, manage, and survive audits on more than $6 billion in federal government contract and grant funding. We’ve been featured presenters and panel moderators at Tech Connect’s National SBIR/STTR conferences since 2010, and I’ve presented at the DOD’s Mentor Protégé Summit and present regularly for several state and local organizations.