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Outgoing Subawards

When the University issues an outgoing subaward funded by a government (federal, state, or local), nonprofit, or foundation entity, the University’s subrecipient may be subject to financial conflict of interest (FCOI) requirements of the prime sponsor. To ensure the University and its subrecipients adhere to these requirements, the following process applies to all outgoing subawards except those funded by for-profit corporations.

At Proposal

  1. The department reviews the Federal Demonstration Partnership (FDP) list of Participating Organizations.
    1. If the subrecipient is included in the FDP list, no further follow-up is needed.
    2. If the subrecipient is not included in the FDP list, proceed to step #2.
       
  2. The department emails the Subrecipient Financial Conflict of Interest Certification (Subrecipient FCOI Certification) form to the subrecipient. (Note: This form was implemented on October 27, 2025 and replaces the former FCOI Form I.)
     
  3. The subrecipient completes the Subrecipient FCOI Certification form and returns it to the department.  
     
  4. The department emails the completed Subrecipient FCOI Certification form to the Conflict of Interest Division (COI Division) at coi@pitt.edu for review and signature.
     
  5. The COI Division reviews the completed Subrecipient FCOI Certification form.
    1. When the subrecipient indicates it does have an FCOI compliant policy (Part II, option A), the COI Division signs the form and returns it to the department.
    2. When the subrecipient indicates it does not have an FCOI compliant policy (section II, option B), the COI Division sends a Subrecipient Investigator Disclosure to all subrecipient investigators identified on the Subrecipient FCOI Certification form. After all subrecipient investigators have completed their Subrecipient Investigator Disclosures, the COI Division signs the form and returns it to the department. (Note: The Subrecipient Investigator Disclosure was implemented on October 27, 2025 and is an online form that replaces the former FCOI Form II.)
       
  6. The department uploads the completed and signed Subrecipient FCOI Certification form to the MyFunding proposal (FP) record.

At Award

The following requirements apply only when the subrecipient indicated in the Subrecipient FCOI Certification form that it does not have an FCOI compliant policy (Part II, option B).

  1. OSP sends an ancillary review request to the COI Division.
     
  2. The COI Division will review the Subrecipient Investigator Disclosures that were completed at proposal to determine if there are any potential FCOIs that require management. If so, the COI Division will work with the subrecipient investigators to implement conflict management plans.
     
  3. The COI Division will send the University Subrecipient Investigator Financial Conflict of Interest Training to subrecipient investigators for completion and signature via DocuSign.
     
  4. When step #2 and #3 requirements have been fulfilled, the COID will complete the ancillary review.