COGR, AAU, and APLU Letter to DOE on Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements

The Association of American Universities (AAU), Association of Public & Land-Grant Universities (APLU), and COGR submitted comments to the Department of Energy (DOE) regarding its proposed rule on Financial Assistance Regulations related to Conflict of Interest (COI) and Conflict of Commitment (COC) policies. They argue that the proposed requirement for institutions to develop stand-alone COC policies is unnecessary, duplicative, and imposes undue administrative burden, given that current DOE and government-wide mechanisms effectively address such concerns through harmonized disclosure processes aligned with NSPM-33 and other federal guidelines. The associations further recommend that DOE maintain and improve its Interim COI Policy—due to its alignment with Public Health Service (PHS) regulations and cross-agency consistency—rather than implementing a new, substantively different rule, as this will better support researcher compliance, reduce institutional workload, and prevent confusion, especially for researchers working with multiple federal agencies.