cover image: Submitted electronically to To: From: Date REFinancial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy

Submitted electronically to To: From: Date REFinancial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy

16 Aug 2024

For every activity, list the following items: • The sponsor of the activity or the source of funding • The award or other identifying number • The title of the award or activity. [...] To reduce this institutional burden and to promote cross-agency consistency that facilitates researcher compliance, we urge DOE to retain the DOE Interim COI Policy and adopt the suggested changes to that policy specified below, or alternatively, align the provisions of the NPRM more closely with the PHS Regulations. [...] (7) With regard to reimbursed or sponsored travel, the non-Federal entity's COI and COC policy must require, at a minimum, reporting the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration. [...] (b) DOE may require the non-Federal entity to provide associated disclosures, supporting documentation to demonstrate how the COI or COC was managed or reduced; and sufficient information to enable DOE to understand the nature and extent of the COI or COC, and to assess whether the actions are sufficient to ensure the integrity of the DOE-supported project and to protect the government's interests. [...] Subsection (a)(1) states that a non-Federal entity may be considered non-compliant if it “fails to sufficiently manage or mitigate a COI or COC to ensure the integrity of the DOE-supported project or to protect the government’s interests.” This standard is incredibly vague given that the terms “integrity” and “protect the government’s interests” are undefined, exceedingly broad, and in the case of.

Authors

Chris O'Leary

Related Organizations

Office of the President
Stanford University
Pages
15
Published in
United States of America

Table of Contents