Carnegie Mellon University

Guidance for Subcontractors and Consultants

Sub-contractors, consultants, and other collaborators do not routinely have to disclose conflicts of interest or outside activities to ORIC for research that is not funded by a PHS agency or the DOE, or an agency that requires an organizational conflict of interest (OCOI) statement. Guidance for those special cases is below.

There maybe other case-by-case situations where a subcontractor or consultant may be asked by ORIC to provide a disclosure to CMU, for example if a specific solicitation or sponsor requires it

For work that is funded by a PHS agency or the DOE, subcontractors and consultants must comply with sponsor regulations regarding conflict of interest, but that does not necessarily mean disclosing to CMU. If CMU has verified that the subcontractor or consultant complies with sponsor FCOI regulations, then they are not required to disclose to CMU. Consultants or sub-contractors whose compliance with FCOI regulations has not been confirmed must disclose to CMU using the External Collaborator form available for download from the ORIC website.   This disclosure must be made before the proposal is submitted.

Training on conflict of interest issues is also required for collaborators from another university if CMU has not verified their compliance with FCOI regulations, but we will not ask your collaborators to complete training until an award is made.  After an award is made we will request training and then disclosures at least annually for the life of the award.

Organizational conflict of interest (OCOI) requirements, most often seen in DARPA or IARPA solicitations, may require that our subcontractors or consultants certify a statement about potential OCOIs.  The specific required form or language depends on the solicitation.  Notify ORIC via if you find this language in a solicitation.