The document is a formal letter from the Council on Governmental Relations (COGR), an association representing 190 research universities and related organizations, addressed to Karen Murphy at the U.S. Fish and Wildlife Service. The letter expresses concern over the conflict of interest (COI) requirements specified in Funding Opportunity Announcement (FOA) F15AS00464. COGR highlights several issues: the FOA lacks references to an official Fish and Wildlife Service COI policy and omits necessary definitions, such as what constitutes a conflict of interest or close personal relationships. Moreover, it shifts responsibility for COI review and management from recipient institutions, which traditionally possess required expertise and established processes, to the Service itself. This deviates from practices of other federal agencies like the Public Health Service and the National Science Foundation.
COGR argues that requiring all potential COIs to be disclosed at the time of application is impractical given the volume of submissions and the fact that not all proposals result in funding, making the requirement overly burdensome. Furthermore, the provision allowing the Service to impose severe remedies for non-compliance, such as suspension or debarment, raises concerns due to its lack of specificity and the absence of procedural recourse for recipient institutions. The letter requests clarification on several key points, including the types of COIs the Service is seeking, definitions of critical terms, disclosure expectations, evaluation criteria, and reconsideration of reference to the remedies. COGR closes by expressing willingness to collaborate to address these ambiguities, referencing successful resolutions with other federal agencies in the past.
