Does the regulation apply to subgrantees, collaborators of grantees (e.g. consortia) or subcontractors?
Yes. The regulation is applicable to each Institution that applies for NIH grants or cooperative agreements for research or submits a proposal for a research contract whether in response to a solicitation or otherwise and, through the implementation of the regulation by each Institution, to each Investigator participating in such research. Accordingly, Institutions carrying out NIH-funded research through subrecipients (e.g., contractors, collaborators) or subcontractors must take reasonable steps to ensure that Investigators working for such entities comply with the regulation, either by requiring the Investigators to comply with the awardee Institution’s policy or by requiring the entities to provide appropriate assurances to the awardee Institution. Subrecipients/subcontractors must report identified FCOIs to the awardee Institution; the awardee Institution must report to the NIH the existence of any conflicting interests arising from subrecipients/subcontractors and assure that the
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