New COI Review Process at JIT and RPPR stages in response to NIH Notice NOT-OD-19-114, which provided clarifications on Other Support, FCOI and Foreign Components
JIT Stage
- A COI review for Other Support/Current and Pending Support and Foreign Components for all senior/key personnel on a project will now be conducted at JIT stage for federal submissions, whether or not the federal sponsor requests Other Support/Current and Pending Support information as part of the JIT.
- The URA Pre-Award RA will prompt the COI Office to conduct a COI review for Other Support/Current & Pending Support, Foreign Components via Ancillary Review in AURA.
- After review, the COI Office will send an email outside of AURA to the Departmental Admin (RC/AC) and the URA Pre-Award RA with instructions to add information to the senior/key personnel’s Other Support/Current & Pending Support and Foreign Components.
- The COI Office will also submit the Ancillary Review in AURA to complete the process.
- The Departmental Admin (RC/AC) will work with senior/key personnel to ensure that their documentation includes the items cited by the COI Office.
- The URA Pre-Award RA will review the Other Support/Current and Pending Support document and review for any items cited by the COI office.
RPPR Stage
- When URA sends out the Monthly RPPRs Due list to campus, the COI Office will review disclosures for all senior/key personnel.
- COI Office will email the Unit (PC-O role) and cc’ the post-award RA with information from the disclosures that relate to Other Support/Current and Pending Support and Foreign Components.
- The Unit will work with senior/key personnel to ensure that their RPPR includes the items cited by the COI Office.
- The URA Post-Award RA will review the Other Support/Current and Pending Support document and review for any items cited by the COI office.
- “No news is good news”.
- Turnaround time will be within two weeks of URA’s email with Monthly RPPRs Due.
