Updated Procedures for Outgoing Subawards and FCOI Compliance

As announced in the Office of Research Protections (ORP) 10/29/25 newsletter, the Conflict of Interest (COI) Division has revised its procedures to strengthen compliance with financial conflict of interest (FCOI) requirements for outgoing subawards.

  • Expanded Scope: FCOI requirements, previously limited to Public Health Service (PHS)–funded subawards, now apply to all outgoing subawards administered by the Office of Sponsored Programs Grants Management Services or Federal Contract Services teams. These include subawards funded by federal, state, or local government agencies, nonprofits, and foundations, but excludes for-profit/corporate agreements managed by the Contracts Services team.
  • Streamlined Process: Subrecipient FCOI forms have been simplified, and there is a new Subrecipient Financial Conflict of Interest Certification (Subrecipient FCOI Certification) form (Note: This form was implemented on October 27, 2025 and replaces the former FCOI Form I.).

Additional information and the step-by-step process are available on the Outgoing Subawards page of the COI website.

For questions, contact the COI Division at coi@pitt.edu.


FEDERAL AGENCY ROUNDUP

Stay up-to-date and informed by visiting the Pitt Research Executive Orders and Federal Funding website.

Date

Friday, November 14, 2025