The document is a formal communication from the Council on Governmental Relations (COGR), an organization representing major research universities, to officials at the White House Office of Management and Budget (OMB). COGR expresses appreciation for prior collaborative efforts which have resulted in improvements to federal research administration policies. However, the letter outlines significant ongoing concerns regarding the interpretation and application of §200.112 of Uniform Guidance, which addresses conflict of interest (COI) for federal awards. COGR highlights that the lack of clear, harmonized federal definitions and inconsistent agency requirements create confusion and administrative burdens for research institutions. Specific issues include varied timing and scope of disclosures, inconsistent definitions of COI and related terms, and requirements that often do not align with established best practices in research environments.
The letter provides a comparative overview (including an appendix) of how various federal agencies implement COI requirements, illustrating wide disparities in disclosure timing, individuals required to disclose, and the standards used for managing conflicts. COGR makes several recommendations to OMB: delay implementation of §200.112 to coincide with procurement regulations, clarify FAQ guidance around subrecipient involvement, harmonize COI-related definitions across agencies, limit disclosures to those with substantive research responsibility, time COI reviews more pragmatically, and accept the viability of managing (rather than only avoiding) conflicts of interest. COGR proposes these measures to promote both regulatory consistency and administrative efficiency while maintaining effective oversight, and expresses willingness to continue working with OMB and agency partners toward a more streamlined and constructive regulatory framework for conflicts of interest in federally funded research.
