The document is a formal communication from the Council on Governmental Relations (COGR), representing 190 research universities, to the Environmental Protection Agency (EPA) regarding the agency’s Interim Conflict of Interest (COI) Policy issued in early 2015. COGR expresses appreciation for the opportunity to provide feedback but raises concerns over the policy’s immediate implementation without adequate input from the research community. The organization highlights that the new policy imposes significant and unnecessary administrative burdens on grant recipient institutions, particularly regarding requirements for conflict of interest inquiries and disclosures prior to proposal submission, which go beyond established federal regulations in 2 CFR 200.318 and 200.112.
COGR’s main criticisms focus on the redundancy and inefficiency of requiring project-level COI disclosures and inquiries for every grant application, irrespective of funding outcomes, and the expansion of disclosure obligations to areas not directly tied to financial transactions or expenditures under federal awards. The letter requests the removal or modification of several provisions, including pre-award inquiry requirements and additional disclosures about EPA employee involvement in proposal preparation. COGR further suggests aligning definitions within the policy (such as “Immediate Family” and “COI Point of Contact”) with existing federal and state standards to reduce confusion and administrative work. The organization reiterates its willingness to collaborate with EPA to refine the COI policy to better reflect practical research administration, reduce unnecessary workload, and ensure compliance without excessively burdensome procedures.
