We need to submit disclosures for three subaward partners as part of a program. Does EACH subaward partner need to submit ONE disclosure or do ALL individuals from each subaward need to submit a disclosure?

 All Investigators on each subaward will be required to complete the training and disclosure requirements. An Investigator means any person who shares the responsibility of Conducting Research. Conducting Research includes the design, development, testing, evaluation, conduct, reporting, review, and oversight of a program of scientific inquiry.  Each Investigator will need to submit an individual disclosure.

In case helpful, below is a brief overview specific to subrecipients but more Information for Non-UA Subcontractors, Consultants, and Collaborators can  be found on our website.

Subrecipients will be presented with two options. They will need to either (1) have an implemented and enforced federally-compliant conflict of interest policy and process and agree to be responsible for compliance under their policy and pursuant to the subcontract or consulting agreement including reporting requirements (our office reviews each subrecipient’s policy to determine it is compliant) or (2) comply with UArizona’s Conflicts of Interest & Commitment Policy (more details on the fees that apply can be accessed from link above).  Our office will be in direct contact with the subrecipients to share a complete overview of all the related requirements. Our office will also provide any assistance and guidance the subrecipient may need.


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