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Faculty-Affiliated Companies: Week 2 |
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FACs and Research: Subawards and Subcontracts with UConn |
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Welcome to week two of our series on faculty-affiliated companies. |
We are covering important requirements and processes to help you confidently navigate the laws, policies, and standards that apply when you or your family members have ownership interests or other significant ties to a company.
If you missed week 1, where we defined “faculty-affiliated companies” (FACs) and went over consulting approval, you can view it here.
This week’s focus: FACs and Research: Subawards and Subcontracts with UConn |
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Subaward from a FAC to UConn |
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If a Faculty-Affiliated Company (FAC) sponsors research and wants to subcontract part of that work to UConn, that’s permitted. UConn handles it like any other subcontract - same process, same paperwork.
Because the faculty member is connected to the company, the Financial Conflicts of Interest in Research Committee (FCOIRC) may add extra requirements to ensure the situation is managed appropriately.
Note:
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Subaward from UConn to a FAC |
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If the Principal Investigator (PI) (the main person leading the grant at UConn) has an interest in the FAC, UConn cannot send subcontract funds to that FAC.
If a Co-PI (not the main PI, but another investigator on the grant) has an interest in the FAC, things get trickier:
Normally, state ethics laws say that a state employee (like the Co-PI) can’t have their company contract with UConn. Exception: If the subcontract is to help commercialize an invention or discovery, it can be allowed, but only under strict conditions. You can see the the full explanation of these conditions in the FAC Guidelines. |
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Let's walk through these rules with an example. |
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Meet Dr. Rivera...
a UConn faculty member, who co-founded a biotech startup (a Faculty Affiliated Company, or FAC) based on his research. He received consulting approval from UConn for his work with his biotech company. |
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His startup receives a federal grant and wants UConn to perform part of the work. The company subcontracts a portion of the research to UConn.
This is allowed, but because Dr. Rivera has ties to the company, the Financial Conflicts of Interest in Research Committee reviews the arrangement and may add safeguards (e.g., requiring independent oversight of project deliverables).
Separately, Dr. Rivera applies as the PI for a new federal grant awarded to UConn. He hopes to subcontract part of that award to his own company.
This is not permitted because he has a financial interest in the FAC. |
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However...
Dr. Rivera’s colleague, Dr. Chen, is the PI on a different UConn project, with Dr. Rivera listed as Co-PI. Dr. Chen wants to subcontract part of the award to Dr. Rivera’s FAC to help commercialize an invention. |
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This may be permitted, but only under strict conditions: Dr. Chen must make the decision independently; Dr. Rivera cannot influence or approve the subcontract; the FAC must be qualified and reasonable in cost; and UConn must notify the sponsor of the conflict. |
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FAC → UConn subcontract = generally allowed, but subject to conflict of interest review.
UConn → FAC subcontract = only allowed if the PI has no interest in the company. If a Co-PI does, it’s only allowed under a commercialization exception and with strict safeguards. |
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Next Week's Focus: Purchasing equipment and services from an FAC |
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