Department of Energy (DOE) New Interim Conflict of Interest 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.

Researchers applying for or receiving funding from the DOE, its national laboratories, or the NNSA (National Nuclear Security Administration) will have additional requirements for maintaining compliance with the DOE’s Interim COI policy. In the coming months, Yale’s COI Office will reach out to Yale faculty and employees who are named as PIs and senior/key personnel on DOE proposals or awards with instructions for:

  • Submitting an updated External Interest Disclosure that complies with the DOE disclosure requirements (for the time being, the “PHS” or the “PHS/NSF” pathways will be modified for this purpose).
    • Because the DOE requires a specific certification that must be included in disclosure forms, Yale’s COI Office is working to include this certification in the disclosure process. In the meantime, however, you may be required to submit a separate certification (to be provided to you by the COI Office) each time you submit or update your disclosure.
  • Submitting travel disclosures in accordance with the new DOE requirements.
  • Fulfilling the DOE training requirement (funds cannot be released until the disclosure and training requirements are completed).

According to the DOE’s Interim COI policy, DOE program offices may apply stricter COI requirements and/or exercise discretion to include increased requirements in funding opportunity announcements (FOAs) or in special award terms and conditions. Should you become aware of any such COI requirements, please contact Yale’s Conflict of Interest Office as soon as possible so we can assist you in this regard. (Email: or call: 203-737-5954).

Because the DOE COI requirements also apply to organizations that carry out DOE awards as subrecipients, please consult as early as possible with your Department Business Administrator or Office of Sponsored Projects Proposal Manager when preparing to submit a proposal that will involve subrecipient organizations.