Regulatory Requirements and Resources

Federal Agency Rules

Public Health Service (PHS) Regulations

• • • Responsibility of Applicants for Promoting Objectivity in Research 
    • Financial Conflict of Interest Tutorial

Department of Energy

• • • Interim Conflict of Interests Policy Requirements – It should be noted that DOE’s definition of “investigator” is broader than NIH and includes additional mandatory training for “investigators”. 

Food and Drug Administration 

• • • Rules on Investigator Conflict of Interest

National Aeronautics and Space Administration (NASA)

• • • New Conflict of Interest and Conflict of Commitment Policy for Recipients of NASA Financial Assistance Awards

National Science Foundation (NSF) Regulations

• • • Proposal and Award Policies & Procedures (2023) – See Chapter IX: Recipient Standards

Other Federal Regulatory Guidance

Federal Acquisition Regulations: Organizational Conflicts of Interest

Government Accountability Office: Agency Actions Needed to Address Foreign Influence – Includes recommendations that agencies adopt financial COI and COC requirements for awardees.

National Security Presidential Memorandum-33 (NSPM-33) – Sets forth the requirement that researchers at academic institutions fully disclose information that can reveal potential conflicts of interest and conflicts of commitment.

Guidance for Implementing National Security Presidential Memorandum-33 – Consistent with the NSPM-33, this guidance includes a significant focus on upholding transparency through clearly-articulated requirements and processes for appropriate disclosure of information related to potential conflicts of interest and conflicts of commitment.

Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act – The act includes direction to NSF on clear prohibitions and disclosure requirements around foreign talent recruitment programs and potential conflicts of interest.

Council on Government Relations  

• • • Principles for Evaluating Conflict of Commitment Concerns in Academic Research Version 2.0 September 2021
    • Analyzing Personal Financial and Institutional Conflict of Interest in Academic Research Contexts
    • COGR Response to NASA’s New Conflict of Interest Policy
    • COGR Comparison of the Department of Energy Interim Financial Conflict of Interest Policy and Public Health Service Regulations for Promoting Objectivity in Research
    • Recognizing and Managing Conflicts of Interest