Posted March 31, 2022 by Tiffany Lee
The Department of Energy recently issued a new, interim conflict of interest rule that requires additional compliance components from investigators with current and upcoming DOE funding.
The University of Nebraska-Lincoln’s Research Compliance Services and Sponsored Programs offices are collaborating to update the NUgrant and NuRamp systems, websites, the Collaborative Institutional Training Initiative (CITI) COI training and other information to clarify and ensure the ability to meet the new DOE requirements.
The new policy closely mirrors COI requirements that have been in place for the last decade for recipients of Public Health Service funding. For Nebraska researchers with current or upcoming DOE funding, the new requirements have the following impact:
- A COI/conflict of commitment disclosure must be, at a minimum, in “submitted” status in NuRamp at the time of DOE proposal submission. RCS and OSP staff are working together to ensure impacted personnel are notified of and meet these requirements at the time of submission and upon award.
- Personnel meeting the DOE definition of an investigator must have an approved disclosure and completed CITI COI training at the time of award. Funds cannot be released until the disclosure and training are approved and completed.
- Sub-awardees involved in a DOE project must certify they are compliant with these requirements. If they are not compliant, they can agree to follow UNL’s disclosure policies and procedures.
- DOE requires a specific attestation that must be included in disclosure forms. RCS is working to include this update in the NuRamp disclosure process.
CITI COI training, once completed, is good for four years before renewal is required. If impacted personnel have never completed this training before or if training has expired, RCS strongly recommends completing training as soon as possible, prior to any funding needs, to prevent award delays. Personnel also should make sure their NuRamp COI/COC disclosure is completed and up to date.
Questions about these new requirements can be submitted to conflict of interest staff.