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.
Ed Jameson, CPA, Managing Member
With over 40 years of experience as a government funding award accounting specialist, Ed is a recognized national expert in the field. In addition to helping hundreds of clients navigate FAR Part 31 compliance. he has been an active speaker and panel moderator at Tech Connect's National SRIR/STTR conferences since 2011. presents at the DOD's Mentor Protégé Summit and presents regularly for several state and local organizations.