UC Comment Letters

This comment letter responds to DOE's proposed "Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements", published on June 18, 2024. UC appreciates DOE’s effort to strengthen research integrity but urges DOE to align its final conflict-of-interest policy with the longstanding PHS COI regulations, preferably by finalizing the existing DOE Interim Policy with targeted changes rather than creating divergent requirements. UC specifically recommends removing conflict-of-commitment requirements from the COI policy, using existing biographical sketch/current and pending support disclosures for COC information, adopting PHS-style definitions and thresholds, shifting reporting to before expenditure of funds, clarifying disclosure obligations, and allowing one year for implementation.