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.
Effective July 1, 2014, the University will be following several new policies concerning subrecipients, including revised monitoring and risk assessment standards. To assist JHSPH personnel in their understanding of the new procedures, ORA is hosting a guest lecture by Rick Inglis, Assistant Director in Financial Research Compliance, who will help us navigate through the various changes. We hope to see you next Wednesday!
Today’s post is the seventh in a series that looks at all facets of research administration within the Bloomberg School of Public Health.
After all of the webinars, articles and presentations, we are now only two days away from the new NIH regulations on Financial Conflicts of Interest taking full effect. As a reminder, these regulations apply to each Notice of Award received from the Public Health Service (PHS) of the DHHS and any related unit, most notably NIH.
When the Transparency Act side-swiped everyone with FFATA and the new FSRS reporting system, the schools at Johns Hopkins banded together to develop a basic plan for how to handle the new regulations and maintain compliance.
As skilled as your institution’s PIs are at their respective concentrations, more often than not, he or she will need to bring in outside organizations to perform certain portions of a given award. Consequently, properly contracting with subrecipients is one of the lynchpins of ensuring an effective and efficient Research Administration office, and we’ve previously discussed many sub-related issues.
Under the revised ForeignFunding Accountibility and Transparency Act (FFATA) foreign subrecipients under Federal awards issued after 10/1/10 receiving over $25,000 must now have a DUNS # and CCR registration for federal regulatory compliance and reporting purposes.
Subrecipients are an integral part of the research process, and here at the Bloomberg ORA we process roughly one thousand subagreements each year alone. By themselves, the subs would take up a substantial amount of our office’s time, but when you factor in the additional contracts, grants, MOUs and assorted other agreements that come across our desks, it’s easy to see why caffeine and baked goods are the staples of each of our diets.