The document is a formal letter dated April 8, 2016, from the Council on Governmental Relations (COGR), representing 190 research universities and institutes, to Mr. James McCaffery at the Department of the Interior (DOI). In the letter, COGR addresses concerns regarding the proposed Financial Assistance Interior Regulation (FAIR), focusing on how conflict of interest (COI) policies are structured and defined. COGR highlights that the DOI's proposed approach shifts the responsibility for COI review and mitigation from the recipient institutions, which traditionally possess the necessary expertise and information, to DOI Grants Officers and Ethics Counselors. COGR argues this change is inconsistent with established federal policies and may hinder effective conflict management because DOI personnel lack access to the nuanced context required for such decisions.
Additionally, COGR expresses reservations about the proposed regulation's definitions, particularly the broad characterization of "conflict of interest," the introduction of terms such as "personal" and "organizational" conflicts, and the inclusion of ambiguous or excessive definitions like "close personal relationship." The letter advocates for aligning DOI’s policy definitions with those in other federal agencies to minimize administrative burden and ensure clarity. COGR’s recommendations aim to uphold effective conflict of interest management, maintain consistency with federal guidance, and ensure distinctions between contractual and financial assistance agreements are preserved. The letter concludes with an offer for continued dialogue and expresses appreciation for the opportunity to provide input.
