This document presents a detailed comparative analysis of the Department of Energy’s (DOE) Interim Conflict of Interest (COI) Policy for Financial Assistance and the Public Health Service (PHS) regulations for Promoting Objectivity in Research (42 CFR Part 50, Subpart F), conducted by COGR as of August 27, 2022. The analysis uses the DOE policy as the base text, highlighting differences and alignments with PHS regulations, particularly concerning standards and requirements designed to ensure that research funded under DOE financial assistance awards is conducted free from bias related to financial or organizational conflicts of interest.
The DOE Interim COI Policy applies to all non-Federal entities receiving DOE financial assistance, detailing responsibilities for disclosure, management, and reporting of significant financial interests that might reasonably appear to affect the objectivity of funded projects. The policy requires that each organization maintain accessible, up-to-date COI policies, inform and train Investigators, secure appropriate subrecipient compliance, and designate officials to oversee disclosures. The document defines key terms, sets thresholds for significant financial interests, prescribes timelines and content for disclosures and annual reporting, and addresses both individual and organizational conflicts of interest. Enforcement mechanisms, sanctions, and remedies for noncompliance are outlined, with specific procedures for retrospective review and reporting in cases of policy violations. The policy’s requirements are incorporated into DOE funding announcements and award terms, mandating that recipients certify compliance and apply these standards to all subrecipients, thereby promoting transparency and accountability in DOE-funded research activities.
