Comment Letter

COGR Letter to DOD on COI Requirements

The document represents a comprehensive guide and formal communication pertaining to the procedures, requirements, and regulatory framework for submitting medical research proposals to the U.S. Department of Defense’s Defense Health Program, particularly those managed by the U.S. Army Medical Research and Materiel Command (USAMRMC). It consists of detailed application instructions, policy clarifications, and a broad agency announcement (BAA) outlining the priorities and compliance expectations for extramural research funding.

A central theme is the balance between advancing military medical research priorities and ensuring robust regulatory compliance. The document delineates the diverse areas of research supported—including combat casualty care, clinical and rehabilitative medicine, medical technology innovation, chemical and biological defense, and emerging health threats—emphasizing the translation of scientific advances into military and public health practice. It defines eligibility for applicants, which includes a wide variety of domestic and international institutions, and outlines a rigorous, multi-stage review process combining scientific merit evaluation with alignment to military relevance and programmatic priorities.

Administrative and ethical compliance is a core focus. The document specifies detailed requirements for proposal formatting, supporting documentation, intellectual property management, and proper budget development. Special emphasis is placed on conflict of interest (COI) policies: the Council on Governmental Relations (COGR) formally urges the reduction of administrative burden by aligning COI disclosure requirements with those of the National Science Foundation (NSF), suggesting disclosures occur at award rather than proposal submission, and seeking limits to the application of certain procurement regulations to assistance awards. The document further mandates adherence to federal statutes and policies covering human and animal research protections, data sharing, fiscal accountability, anti-lobbying standards, and safeguarding of vulnerable populations.

The guidance highlights procedural rigor, requiring institutional registrations, careful preparation of application materials, and observance of strict submission timelines. The evaluation and award process is structured to ensure both scientific integrity and strategic programmatic fit, with transparency in outcome decisions and mechanisms for appeal. Post-award compliance is closely regulated, including technical, fiscal, and ethical reporting, as well as ongoing oversight of any research involving regulated subjects or hazardous materials.

In summary, the document establishes a robust legal, administrative, and ethical infrastructure to support innovative and impactful medical research serving military and public health needs, while also reflecting ongoing efforts to streamline administrative processes and harmonize federal requirements. Through its detailed protocols and policy advocacy, it seeks to foster collaboration, ensure research integrity, and maximize both scientific and operational impacts.