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Rule 1-006C of the University of Utah's Individual Financial Conflict of Interest Policy 1-006 requires that all Subrecipients certify that they abide by a financial conflict of interest policy that is equivalent to the University's policy (1-006 and associated regulations). 

“Subrecipient” means an individual or entity that acts as a subcontractor, subgrantee, or subawardee for Research.

Subrecipients who cannot provide this certification are required to abide by the University of Utah's policy (1-006 and associated regulations), regardless of the primary funding source of the award, and in doing so they agree to follow the procedures outlined below for COI review to occur prior to the subaward being fully executed. COI review must occur before the project initiates and on a recurring basis (at least annually). Procedural compliance is required for continued processing of the subaward.

INSTRUCTIONS (when Subrecipients utilize University of Utah's COI policy)

STEP 1: Identify Subrecipient Investigators

The local Principal Investigator should obtain a list of all Investigators from the Subrecipient site. The information required is: Last Name, First Name, Date of Birth, Email Address. Additional useful information is: Address, City, State or Province, Country, Phone. This information should be submitted online in the Subrecipient Commitment Form of OSP's eAward system, or submitted to the COI Office if requested.

STEP 2: COI Office will request affiliate status for Subrecipient Investigators and establish ERICA access

The COI Office will request affiliate status for all Subrecipient Investigators through the Univeristy of Utah's Human Resources website using the following guidelines:

Request Type: Request Affliate

Personal Information: (As provided by the Subrecipient site)

Department Information/Exit Date: The default expiration date for an affiliate uNID is 1 year from the application date. We recommend that you make the expiration date 3 years from the start date. If you wish the uNID to be valid for less than 1 year, change the end date to reflect the duration required. To extend an exit date after the uNID is established, use the same link above, but choose "Extend Affiliate Access." The "Extend Affiliate Access" can only be completed while the Affiliate uNID is still active. If the uNID has already expired, you will need to redo the initial request.

Department Information/Affiliate Type: 10018 ERICA IRB Online

Department Information/Authorizing Department: 01491 AVP Research Integrity

Obtaining this affiliate status will establish a University ID ("uNID") for each Investigator, which is required for the financial disclosure and COI review process. The COI Office will notify the Subrecipient Investigators of the newly established uNID, so that the Subrecipient Investigators may perform the next steps. 

STEP 3: Subrecipient Investigators file financial disclosures

Once the uNID is received, each Subrecipient Investigator must file a financial disclosure in the University of Utah's Business Relationship Reporting system ("BRR"):

A) Finalize your University account by changing your password

Passwords are created through Campus Information Systems ("CIS"). Please go to and use the uNID as the username with a lowercase u replacing the first zero. The initial temporary password will be the birth date in the format MMDDYY with no dashes, slashes, or spaces. You will then need to change your password and set security questions. 

If access has been added to an existing uNID and the original password is forgotten, or for any other issues logging in, please contact the Campus Help Desk at 801-581-4000. They can reset the password to your DOB.

B) BRR training & disclosure

File a financial disclosure at Training on the University of Utah's financial conflict of interest policy must first be completed within the BRR system before beginning the financial disclosure. Then, fill out the financial disclosure form as instructed in the system, and certify the disclosure. The financial disclosure must be uptated within 30 days of a change in financial relationships and at least annually.

STEP 4: Respond to additional correspondence 

COI reviews are performed in the Electronic Research Integrity and Compliance System ("ERICA"), and additional information may be requested through this portal. If so, you will receive an email notification with a link to the portal to complete the request. You will log on to using your CIS password. If a management plan is implemented due to a conflict of interest, you must accept the management plan to complete the COI review. Further review will occur on an annual basis for the duration of the project. Please contact the COI Office with any questions about this process. 

STEP 5: COI Office will notify OSP when reviews are complete

The COI Office will notify the Office of Sponsored Projects when all COI reviews have concluded for the subaward, so that further processing may continue at that time. 

Last Updated: 5/3/23