Federal and other COI Requirements and Guidelines

    New Department of Energy Interim COI Policy

    On December 21, 2021, the Department of Energy (DOE) issued its new Interim Conflict of Interest Policy. This new policy establishes standards that provide a reasonable expectation that the design, conduct and reporting of projects funded wholly or in part by the DOE “will be free from bias resulting from financial conflicts of interest or organizational conflicts of interest.” The new DOE policy closely mirrors the COI requirements that have been in place for recipients of Public Health Service (PHS) funding. Read more.

    Some federal and non–federal sponsors include in their award terms and conditions financial interest/conflict of interest disclosure requirements. Listed below are some of the sponsors with such requirements. By clicking on the sponsor, you will be able to review that sponsor’s requirements.

    Transactional Review

    In order to determine if a financial interest is a conflict of interest, the Conflict of Interest Committee performs a “transactional” review of an individual’s external financial interests to the work described in the proposal. Read more detailed information regarding transactional reviews and the process below.

    What is a transactional review?

    If any significant financial interests are identified in your disclosure, these interests will be compared to each new research award on which you are identified as responsible for the design, conduct, or reporting of the research to determine if a COI exists related to that research award. This is called a “transactional review”. Certain sponsors require that they be notified of the existence of a conflict of interest and require details about the nature of the FCOI and the management plan.

    Federal Regulations

    Non–Federal Requirements

    Publication Requirements