The Sponsored Projects Office has made some necessary changes to the Subrecipient Commitment Form under “Section F: Certifications 6. Conflict of Interest.”
This change was needed because subrecipients without an active and enforced conflict of interest policy consistent with the provisions of the National Science Foundation or the Public Health Service are no longer going to be allowed to rely on Berkeley’s Conflict of Interest policy.
All subrecipients now will have to have an appropriate COI policy in place prior to Berkeley issuing a subagreement under a prime award from NSF/PHS or any organization that has adopted the PHS or NSF Conflict of Interest requirements.
This is explained under Section F: Certifications 6. Conflict of Interest.
Important: Before a proposal is submitted to the NSF or the PHS or any organization that that has adopted PHS or NSF COI requirements, subrecipient investigators (as defined by applicable regulations) from entities without an active an enforced conflict of interest policy must complete the PHS Financial Disclosure (Form 5) or the NSF Financial Disclosure Form (as appropriate) and attach it to the Subrecipient Commitment Form before it is submitted to SPO. Failure to do this will prevent the submission of the proposal.
The new Subrecipient Commitment Form dated (12/2015) must be used by January 15, 2016. All other versions of the Subrecipient Commitment Form submitted to SPO after this date will be returned.
During the interim period, the previous version of the form will be accepted by SPO as long as a new Section F: Certifications 6. Conflict of Interest also is provided with appropriate disclosure forms.
