Special FCOI Requirements for DOE Researchers

In July 2026, the U.S. Department of Energy (DOE) released a new set of “Conflict of Interest and Conflict of Commitment Policy Requirements,” effective August 17, 2026. The regulation, which is incorporated as an Appendix B to the University's FCOI and Research Policy, includes specific requirements for researchers funded by DOE and those applying for such funding. These requirements include disclosure requirements for both conflicts of interest (COI) and conflicts of commitment (COC), special certification language in the annual disclosure form (filed in Rascal); special requirements for reporting sponsored travel, and a requirement for all DOE researchers to complete training in COI and COC at least once every two years.

Prior to the August 17, 2026 effective date of the new DOE COI/COC policy, DOE research was governed by DOE’s Interim COI Policy, incorporated into a prior version of Appendix B. Awards received before August 17, 2026 remain subject to COI requirements specified in their award terms and conditions until such time as DOE modifies the award terms and conditions to include the new COI/COC requirements. RCT and SPA will be in contact with individual DOE researchers regarding requirements for compliance.

Training

DOE researchers can complete their initial DOE COI/COC training in Rascal by taking Rascal course TC1450 - Financial Conflicts of Interest and Conflicts of Commitment for PHS/DOE Researchers, a stand-alone FCOI course for PHS- and DOE-funded researchers.

To remain compliant with the DOE COI/COC 2-year training requirement, researchers who have previously completed DOE compliant COI/COC training can complete Rascal course TC1458 - Refresher COI/COC Training for DOE Researchers, an abbreviated FCOI refresher course. (Note that TC1458 is refresher training only and does not satisfy the initial COI/COC training requirement.)