FDP Expanded Clearinghouse Project Aims to Reduce Administrative Burden

In 2011, the Federal Demonstration Partnership (FDP) created a PHS Financial Conflict of Interest (FCOI) Clearinghouse as a mechanism for FDP member and non-FDP member institutions to document that they had a PHS FCOI compliant policy in place. This repository allowed participants to forego the exchange of thousands of individual transaction-specific documents. As of January 2016, 962 institutions are listed in the FCOI Clearinghouse.  The success of this initiative led to the concept of an expanded Clearinghouse that would contain audit, demographic, and fiscal information needed by pass-through entities (PTEs) when they are issuing subawards. The need for a national repository was exacerbated by release of the Uniform Guidance, which expands subaward risk assessment and monitoring obligations. Many institutions created “Subrecipient Commitment Forms” to collect such data, but the proliferation of many different forms collecting mostly similar information has underscored the need for national consistency and a more efficient process.

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Untangling the Memorandum of Understanding

A “contract” is a legally binding agreement that obligates parties to do or not do something.  It can be verbal or written, short or long, formal or informal, general or detailed.  It can fall under a variety of names (agreement, purchase order, letter of intent/commitment/authorization, award, grant) and a spectrum of possible remedies.  Regardless of its name, though, a contract should, at a minimum, identify the parties, the subject, and the “consideration” (motive or inducement); have mutual obligations; and evidence mutual agreement.

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From The Vault: Bringing NDAs Into The Open

confidential[Occasionally, we like to revisit posts from days gone by that either (1) are always relevant, or (2) are the subject of recent questions received by our office.  In today’s From The Vault, we look at Nondisclosure Agreements (sometimes called Confidentiality Agreements), which are frequently used as precursors to the inception of a formal research project.]

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