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.
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. Provide this list to the COI Office (COI@utah.edu). Please reference the proposal ID (DSS number), the transaction ID, and the award dates.
STEP 2: COI Office will request affiliate status for Subrecipient Investigators
The COI Office will request affiliate status for all Subrecipient Investigators through the Univeristy of Utah's Human Resources website https://www.hr.utah.edu/forms/affiliate.php 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 https://cis.utah.edu 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 https://faculty.utah.edu/brr. 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: Subrecipient Investigators register for ERICA access
COI reviews are performed in the Electronic Research Integrity and Compliance System ("ERICA"), and Subrecipient Investigators must self-register for access by logging on to https://erica.research.utah.edu/. Please use your preferred email account when registering, as that account will receive correspondence from the COI Office and response is required. You may select 01491 AVP Research Integrity as your Department.
STEP 5: Notify the COI Office to perform the COI review
Once the above steps have been completed, notify COI@utah.edu that you are ready for COI review to occur. Please provide the DSS number, the name of the Subrecipient organization, and the names with uNIDs of all Subrecipient Investigators. The COI Office will perform the COI review, and additional information may be requested. If a financial conflict of interest is identified, that Investigator must accept any resulting management plan in order for the COI review to conclude. Please contact the COI Office with any questions about this process. 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.