Information for Research Subrecipients & COI Fee Schedule

With respect to any Subrecipient or Consultant agreement awarded pursuant to a federally funded award to the University of Arizona (“UArizona”), subrecipients and consultants must agree to one of the below options:


Option 1

  1. Have an implemented and enforced PHS/NSF compliant conflict of interest policy and process;
  2. Agree to apply that policy to Investigator.  An Investigator is any person who is responsible for the design, conduct, or reporting of work. (An individual’s position, title on the project, employment status (full or part-time), and percentage of effort devoted to the project do not factor into this determination. The term “Investigator” is based upon the person’s independence in the design, conduct or reporting of the research.);
  3. Agree to be responsible for all compliance under their policy and pursuant to the subcontract or consulting agreement; and
  4. Report all Financial Conflicts of Interest and management strategies to UArizona’s COI Office via email (


Option 2

Comply with UArizona’s Conflicts of Interest & Commitment Policy.


Fees for Non-UArizona COI Review & Management

This fee structure applies to non-UArizona Investigators who will comply with UArizona’s Conflicts of Interest & Commitment Policy.  It does not apply to Phase I SBIR and STTR grants.  Fees are based on review, regardless of whether the research is actually initiated.

Initial Submission of COI Disclosure:

  • Initial Admin Review - $160 per Investigator
  • Committee Review - $227 per Investigator

Annual Update of COI Disclosure:

  • Annual Review - $130 per Investigator
  • Committee Review - $230 per Investigator 

Management of Financial Conflict of Interest:

  • Implementation of Plan – Initial Fee + $300 per Investigator
  • Implementation of Management Plan with Independent Monitor – Initial Fee + $430 per Investigator
  • Monitoring Management Plan After First year – Annual Fee + $105