The Association of American Universities (AAU), Association of Public & Land-Grant Universities (APLU), and COGR submitted comments to the Department of Energy (DOE)...
Conflict of Interest/Commitment
Identification, review, and management of researcher and/or institutional financial conflicts of interest (FCOIs) that have the potential to bias the design, conduct, or reporting of research and considerations surrounding researchers’ conflicts of commitments that arise when a researcher’s external activities may interfere with their ability to fulfill their primary obligations to their employing institution.
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COGR Publishes “Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts”
COGR has published a new report on Analyzing Personal Financial and Institutional Conflicts of Interest in Academic Research Contexts.
Resources
Point of Contact
Kristin West
Director, Research Ethics & Compliance
All Conflict of Interest/Commitment Articles
COGR Comparison of the Department of Energy Interim Financial Conflict of Interest Policy and Public Health Service Regulations for Promoting Objectivity in Research
COGR has developed a comprehensive chart that summarizes and compares federal laws, regulations, and policies in the area of science and security. The chart is divided into three separate tabs that cover (a) major federal-wide legislation or policy (e.g., National Presidential Security Memorandum 33, CHIPS and Science Act of 2022); (b) agency disclosure requirements for researchers and re
DOE vs. PHS FCOI Comparison Document
This document presents a detailed comparative analysis of the Department of Energy’s (DOE) Interim Conflict of Interest (COI) Policy for Financial Assistance and the Public Health Service (PHS) regulations for Promoting Objectivity in Research (42 CFR Part 50, Subpart F), conducted by COGR as of August 27, 2022. The analysis uses the DOE policy as the base text, highlighting differences and alignm
DOE Interim Conflict of Interest Policy: June 2022 Meeting
The document presents an overview of the U.S. Department of Energy’s (DOE) Interim Conflict of Interest (COI) Policy as outlined by Michael Zarkin to the Council on Government Relations. The DOE administers an extensive array of R&D and non-R&D programs, employing both discretionary and formula grant mechanisms, and thus its policies must accommodate a diverse range of activities and stake
Guidance Regarding the Without Compensation (WOC) and State Treasury Exceptions to 18 U.S.C. § 209 – Conflicts of Interest: February 2022 Meeting
This document provides detailed guidance on the application of 18 U.S.C. §209, which prohibits federal employees from receiving salary or supplemental compensation from non-federal entities for work performed as part of their governmental duties, with specific attention to Department of Veterans Affairs (VA) research personnel. It outlines the two primary exceptions to this prohibition: the Withou
Principles for Evaluating Conflict of Commitment Concerns in Academic Research (Update)
Updated September 22, 2021This paper examines the issue of conflict of commitment in the context of concerns regarding inappropriate foreign influence, promoting transparency, and avoiding conflicts.
COGR’s Releases Paper on “Foreign Influence—Practical Considerations in Developing an Institutional Response”
This document outlines the increasing federal scrutiny on inappropriate foreign influence in U.S. academic research and offers practical considerations for institutions to develop effective research security responses. Triggered by concerns such as undisclosed foreign funding, participation in foreign government talent programs, and intellectual property theft—especially with a focus on China—U.S.
NIH’s Guide Notice NOT-OD-21-073: Institutional Perspective: June 2021 Meeting
The document provides an in-depth overview of the institutional considerations and practical approaches to implementing the National Institutes of Health (NIH) Guide Notice NOT-OD-21-073, which outlines NIH policies related to reporting of Other Support, financial conflicts of interest, and foreign components in research. Moderated by Kristin West, with panelists from Columbia University, Yale Uni
COI Part 2 Case Studies: June 2020 Meeting
This document presents a case study involving a major public university that faced scrutiny after receiving letters from the NIH regarding undisclosed foreign funding and faculty commitments. The case centers on a professor with significant NIH and NSF funding who engaged in a longstanding, unpaid research collaboration with a foreign institution (UU) and subsequently received an unsolicited honor
