The Council on Governmental Relations (COGR), representing major research universities, addressed the White House Office of Management and Budget (OMB) to articulate ongoing concerns regarding the interpretation and implementation of Section 200.112 of the Uniform Guidance (UG) as it relates to conflict of interest (COI) policies in federal awards. While recognizing positive progress in clarifying and harmonizing federal requirements—such as procurement grace periods and cost sharing—COGR highlights persistent problems stemming from inconsistent agency interpretations of COI, particularly due to the broad and open-ended wording of §200.112. Their concerns involve confusion over definitions, timing and scope of disclosures, the range of individuals required to disclose, and the lack of harmonized or clear agency policies, which challenge universities’ ability to comply efficiently and effectively.
COGR proposes a series of recommendations to address these inconsistencies, including synchronizing the implementation of §200.112 with procurement sections, clarifying FAQs especially regarding subrecipients, harmonizing definitions of conflict types, limiting required disclosures to personnel with substantive research responsibilities, ensuring disclosures and reviews align with funding notification rather than proposal submission, and allowing conflict management through established institutional processes. The organization emphasizes the importance of affordable, minimally intrusive regulatory approaches that leverage existing university expertise without imposing unreasonable burdens. COGR also signals willingness to collaborate on the development of model COI policies and reiterates its commitment to ongoing dialogue and harmonization of agency requirements. An accompanying table illustrates the disparate practices across multiple federal agencies, underlining the urgency of COGR’s request for greater consistency in federal policy enforcement.
