Rule R1-006F: United States Department of Energy Investigator Conflict of Commitment Requirements

Purpose and Scope
Definitions
Rule
‌Policies/ Rules, Procedures, Guidelines, Forms, and other Related Resources‌
References
Contacts
History

‌Purpose and Scope‌
1. Purpose.
  
  This rule establishes the university’s process for managing Conflicts of Commitment for Investigators applying for and conducting Research sponsored by the United States Department of Energy (“DOE”).
2. Scope.
  
  This rule applies specifically to Investigators applying for and conducting research sponsored wholly or in part by the DOE.
  
  This rule does not govern other Conflicts of Commitment that might arise during an Investigator’s duties to the university, which are governed by other regulations (see e.g., Policy 5-204: Remunerative Consultation and Other Employment Activities, Supplemental Rule 1-006: Health Sciences Industry Relations Policy). This rule does not govern financial conflicts of interest, which are governed by other regulations (Policy 1-006).
  
  This rule applies to Subrecipients who are DOE Investigators, as described in Section III.D.
‌Definitions‌

The definitions provided in Policy 1-006 apply to this rule. In addition, the terms below apply for the limited purpose of this rule.
1. “Conflict of Commitment” or “COC” means, as defined in 2 C.F.R. Sec. 910.200, a situation in which an individual accepts or incurs conflicting obligations, whether foreign or domestic, between or among multiple employers or other entities.
  1. Among other things, a COC may include conflicting commitments of time or effort, including obligations to dedicate time in excess of university or DOE requirements; or a conflicting obligation that one might reasonably expect would require or induce the individual to improperly share information with, or withhold information from, the university or the DOE.
  2. Examples of situations that may give rise to a Conflict of Commitment include but are not limited to:
    1. current or pending employment;
    2. positions, appointments, or affiliations, such as titled academic, professional, or institutional appointments, whether remuneration is received and whether full-time, part-time, or voluntary; and
    3. participation in, or applications to, foreign government-sponsored talent recruitment or similar programs.
2. “DOE Investigator” means an Investigator who is applying for or receiving Research funding from the DOE.
3. “Supervisor” means a department chair, dean, or other immediate supervisor who has responsibility and oversight of an Investigator and the Investigator’s roles and responsibilities at the university.
‌Rule‌
1. ‌Disclosure and Training Requirements for DOE Investigators.‌
  1. DOE Investigators must complete training related to COC every two years.
  2. Information submitted in the BRR Disclosure Form is used to assess whether a DOE Investigator has a COC.
  3. Once a DOE Investigator submits a BRR Disclosure Form as required by Policy 1-006, the DOE Investigator is required to update the BRR Disclosure Form:
    1. within the timelines provided in Policy 1-006; and
    2. within 15 days of acquiring any new Financial Relationship, including a Financial Relationship that would result in an actual, potential, or apparent COC.
2. ‌Review, Evaluation, and Management Requirements.‌
  1. Supervisor Review, Evaluation, and Management of Conflicts of Commitment in DOE-funded Research.
    1. A DOE Investigator’s Supervisor must actively review the DOE Investigator’s BRR Disclosure Form and determine whether the DOE Investigator has a COC:
      1. before the DOE Investigator applies for DOE funding;
      2. when the DOE Investigator updates their BRR Disclosure Form; and
      3. throughout the duration of any Research project for which the DOE Investigator receives DOE funding.
    2. A Supervisor is responsible for determining if a DOE Investigator has an actual, apparent, or potential COC.
      1. If the Supervisor determines the DOE Investigator has an actual, apparent, or potential COC, the Supervisor must determine if the COC can be effectively managed and, if so, develop a management plan strategy.
    3. A Supervisor may manage a DOE Investigator’s COC by requiring the Investigator to:
      1. reduce the DOE Investigator’s time or effort associated with the activity, relationship, or commitment giving rise to the COC;
      2. modify the scope of a proposal the DOE Investigator intends to submit to DOE;
      3. disclose the activity, relationship, or commitment giving rise to the COC in publications, presentations, or elsewhere;
      4. notify the DOE contracting officer of the COC; or
      5. comply with any other management strategy the Supervisor determines is necessary to appropriately manage the COC.
    4. A Supervisor must immediately notify the Conflict of Interest Office if the Supervisor determines that a DOE Investigator has an actual, apparent, or potential COC that cannot be effectively managed.
    5. A Supervisor’s determination is final and may not be appealed.
    6. The Conflict of Interest Office will monitor the DOE Investigator’s BRR Disclosure Forms for COCs related to Foreign Government-based Entities.
  2. Reporting to DOE on Conflicts of Commitment.
    1. The university must report identified COCs and management measures to the DOE in compliance with the DOE’s regulations and the reporting schedules and terms outlined in the federal financial assistance award.
3. ‌Confidentiality and Internal and External Dissemination of Information.‌
  1. The information disclosed for a case under this rule (including contents of any BRR Disclosure Form), and the written descriptions of a Supervisor’s determinations in a case concerning a COC, shall be disseminated (or as appropriate, made available) internally within the university to:
    1. the appropriate university offices, including, but not limited to, the following offices (or equivalents): Office of the Vice President for Research; Office of General Counsel; Internal Audit; Institutional Review Board; Office of Sponsored Projects; Technology Licensing Office; Procurement & Contracting Services; Graduate School; and
    2. other Employees whose responsibilities to the university are directly affected by the COC.
  2. Except for the dissemination of information described in this rule and related regulations, the Individual Conflict of Interest Committee and other individuals within the university who have direct responsibility for reviewing potential COCs or investigating potential violations of this rule, including non-compliance with COC management plans, shall treat the information received and considered during these processes as confidential information.
  3. Any information disclosed by a DOE Investigator as required by this rule shall be used solely for the purpose of administering this rule and may not be used for any other purpose unless required by law.
  4. An Employee who violates Section III.C.2 or Section III.C.3 shall be deemed to have engaged in unethical behavior, which is punishable under pertinent university regulations, including Policy 5-111: Corrective Action and Termination Policy for Staff Employees or Policy 6-316: Code of Faculty Rights and Responsibilities.
4. ‌Applicability to Subrecipients‌
  1. For DOE-sponsored Research that involves a Subrecipient, the Office of Sponsored Projects shall enter a written agreement with the Subrecipient that:
    1. requires the Subrecipient to certify that the Subrecipient has a COC policy that is consistent with this rule and complies with DOE regulations;
    2. requires DOE Investigators to comply with the Subrecipient’s COC policy;
    3. specifies the time period(s) for the Subrecipient to report all identified COCs to the university so that the university can provide timely COC reports, as required, to the DOE; and
    4. requires the Subrecipient to make the Subrecipient’s COC policy available via a publicly accessible website, unless the Subrecipient does not have such a website, in which case the Subrecipient shall make its written policy available to any requester within five business days of a request for the Subrecipient’s written policy.
5. ‌Noncompliance.‌
  1. Potential violations of this rule must be reported to the Conflict of Interest Officer.
  2. Violations of this rule will be addressed through the process for addressing conflict of interest violations described in Policy 1-006 and Rule R1-006B.
  3. The Conflict of Interest Officer must promptly notify the DOE of a DOE Investigator’s violation of this rule and the corrective action taken or to be taken.
    
    Sections IV- VII are for user information and are not subject to the approval of the Academic Senate or the Board of Trustees. The Institutional Policy Committee, the Policy Owner, or the Policy Officer may update these sections at any time.
‌Policies/ Rules, Procedures, Guidelines, Forms, and other Related Resources‌
1. Policies/ Rules.
  1. Interim Policy 1-006: Individual Financial Conflict of Interest Policy
2. Procedures, Guidelines, and Forms. [ reserved ]
3. Other Related Resources. [ reserved ]
‌References‌
1. Policy 5-111: Corrective Action and Termination Policy for Staff Employees
2. Policy 5-204: Remunerative Consultation
3. Policy 6-316: Code of Faculty Rights and Responsibilities
4. 2 C.F.R. Sec. 910
‌Contacts‌

The designated contact officials for this regulation are:
1. Policy Owner(s) (primary contact person for questions and advice): Conflict of Interest Officer
2. Policy Officer(s): Vice President and General Counsel and Vice President for Research
  
  See Rule 1-001 for information about the roles and authority of policy owners and policy officers.
‌History‌

Revision History.
1. Current version. Revision 0.
  1. Effective Date. August 17, 2026.
  2. Legislative History
  3. Editorial Revisions
2. Previous versions.
3. Renumbering
  1. Not applicable

Revision 0. Effective Date: August 17, 2026

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