The Council on Governmental Relations (COGR), representing a collective of 190 research universities and affiliated institutions, addressed concerns to the U.S. Fish and Wildlife Service (FWS) regarding the conflict of interest (COI) provisions in a specific Funding Opportunity Announcement (FOA: F15AS00464). COGR emphasizes that while compliance with uniform federal regulations is critical, the FOA’s COI requirements are unclear and place undue administrative and procedural burdens on institutions. Notably, the announcement lacks reference to an established FWS COI policy, offers no definitions for essential terms, and assigns primary responsibility for COI review and management to the agency rather than recipient institutions—contradicting widely accepted practices by other federal agencies such as the Public Health Service and National Science Foundation, which rely on institutional expertise to address COI.
COGR further critiques the FOA’s requirement for disclosure of all known COIs at the application stage, highlighting the impracticality and excessive burden of collecting institution-wide disclosures prior to funding decisions. The organization raises concerns about vague language regarding possible sanctions for noncompliance and seeks clarification on the types and definitions of COIs of interest to the Service, criteria for evaluation, and processes for institutional review. COGR requests that the FWS revise its requirements to better align with established federal standards and accepted institutional practices and expresses willingness to collaborate to resolve these issues, emphasizing recent successes in similar discussions with other federal agencies.
