The document is a formal response from leading organizations in the higher education and research university sector to NASA regarding its proposed new Conflict of Interest (COI) and Conflict of Commitment (COC) Policy for recipients of NASA financial assistance awards. The signatories commend NASA's initiative to enhance research integrity and address both financial and non-financial conflicts but express significant concerns about the policy's structure and implementation. Their primary issues include a lack of alignment with existing COI policies from other major federal research agencies such as the National Science Foundation (NSF) and National Institutes of Health (NIH), as well as the problematic conflation of COI and COC requirements. The commenters argue that the proposed definitions of COI and COC are overly broad, lacking in clear terminology, thresholds, and exclusions, which would place undue administrative burdens on institutions. They emphasize that inconsistencies with established federal standards will complicate compliance, increase costs, and may result in confusion and unintentional noncompliance among investigators.
Furthermore, the document highlights that NASA's approach would duplicate disclosure and reporting processes already addressed in the National Security Presidential Memorandum 33 (NSPM-33) Implementation Guidance and forthcoming standardized federal forms. The response strongly recommends that NASA instead model its COI policy on existing, well-understood NSF or NIH frameworks, which would harmonize requirements across agencies and allow research institutions to utilize current processes and tools. The letter also suggests that COCs should be managed through separately structured disclosures in accordance with NSPM-33, rather than being merged with COI policies, to avoid redundancy and ambiguity. The detailed comments on NASA's policy provisions further underscore the need for clear definitions, appropriate scope, and tailored handling of foreign influence concerns. In conclusion, the organizations urge NASA to adopt a more consistent, streamlined approach that builds on proven federal models, thereby facilitating efficient, effective compliance and supporting the integrity of federally funded research.
