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Subrecipient Processes for Financial Conflicts of Interest

Overview

When subawarding or subcontracting to an external entity, Virginia Tech must apply relevant financial conflict of interest (FCOI) requirements of the originating sponsor to subrecipients. Therefore, if required by the originating sponsor, Virginia Tech must identify whether the subrecipient has an FCOI policy that is compliant with the applicable originating sponsor’s requirements.

The Office of Sponsored Programs is required to verify, by way of a written agreement with subrecipient institutions on projects sponsored by the Public Health Service (PHS), National Science Foundation (NSF), Department of Energy (DOE), or National Aeronautics and Space Administration (NASA), whether the university’s policy (No. 1045) or the FCOI policy of the subrecipient will apply to its investigators who are collaborating with Virginia Tech investigators. As a rule, Virginia Tech will require subrecipient institutions to maintain and administer their own FCOI policies and will only in exceptional circumstances assume primary responsibility for directly soliciting and reviewing subrecipient disclosures to make an FCOI determination.

If the subrecipient uses Virginia Tech’s policy, the subrecipient must adhere to procedures and time frames established by the university. The subrecipient will enter into a written agreement requiring its investigators to report significant financial interests to Virginia Tech and complete the FCOI training requirement.

Separately, Virginia Tech investigators must disclose to Virginia Tech relationships with subrecipients, consistent with the university’s policy for conflicts of interest and commitment (No. 1045).

Procedures for the Office of Sponsored Programs

All FCOI requirements must be met prior to Virginia Tech issuing the subaward or subcontract. To comply with federal FCOI regulations, the following procedures should be followed prior to the release of funding:

  1. For a subrecipient under a PHS, NSF, DOE, or NASA prime award, if the Subrecipient is a member of the FDP Clearinghouse, the Office of Sponsored Program will check their profile to confirm they have certified to an active and enforced FCOI policy consistent with the requirements of PHS, NSF, DOE, or NASA.
    • If the subrecipient will follow their policy and identifies any financial conflicts of interest related to the project, it will forward its FCOI report(s) to Virginia Tech's administrative contact by the time specified on Virginia Tech's form. Virginia Tech's Office of Sponsored Programs (or the Research Conflict of Interest program) will submit all required FCOI reports to the prime sponsor prior to execution of the subaward.
  2. If a subrecipient is not an FDP Clearinghouse member, they must complete the Virginia Tech subrecipient data form for non-FDP members. They will indicate on the form whether they have an FCOI policy that is consistent with the prime sponsor's requirements. 
    • As a rule, Virginia Tech will require subrecipient institutions to maintan and administer their own FCOI policies and will only in exceptional circumstances assume primary responsibility for directly soliciting and reviewing subrecipient disclosures to make an FCOI determination. 
  3. If the subrecipient indicates on the subrecipient data form that it does not have a policy consistent with the prime sponsor's requirements, then the subrecipient will be required to follow Virginia Tech's policy (No. 1045). In this case, the Office of Sponsored Programs will alert the Research Conflict of Interest program so that the program can directly solicit and review subrecipent disclosures to make an FCOI determination prior to the university's issuance of the subaward.