The document summarizes discussions from the October 24, 2019, COGR (Council on Governmental Relations) panel on Conflict of Commitment (COC), focusing on evolving federal requirements and institutional responses. The National Institutes of Health (NIH) and National Science Foundation (NSF) have both recently expanded disclosure requirements for researchers, mandating comprehensive reporting of all research support, including non-financial resources, outside professional activities, appointments, and in some cases, consulting and lab visitors. A survey of COGR committees revealed most institutions have written COC policies, with many requiring disclosure and approval for external appointments, as well as procedures for auditing and monitoring disclosures, especially regarding sponsored travel and high-risk areas.
Presentations from representatives of Washington State University, Michigan State University, Case Western Reserve University, and Florida State University detail the varying institutional policies and practical challenges encountered. Approaches range from centralized electronic disclosure systems and preset caps on outside engagements to informal or incomplete processes constrained by limited resources. Several institutions highlighted gaps in existing policies—such as ambiguity around non-compensated activities, non-financial resources, and the overlap with collective bargaining agreements—and emphasized the need for increased faculty education, additional monitoring mechanisms, and possible policy adjustments in light of new federal expectations. Overall, the discussion underscored the growing complexity of managing conflicts of commitment in the academic research environment and the imperative for clear guidelines, robust disclosure processes, and institutional cooperation to ensure compliance and integrity.
