COGR, AAU and APLU have filed a joint response letter to the Department of Energy Notice of Proposed Rulemaking on Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements. Several institutions have contacted us about potentially filing comments that support the COGR letter. If you are interested in supporting the COGR letter, we have attached a copy and you can also review it at Regulations.gov using the following Comment Tracking Number lzw-t31l-74m7it under matter number DOE-HQ-2024-0029, RIN1991-AC18. Comments are due on August 19, 2004.
Additionally, per institutions’ requests, we have included sample text for a support letter below for your consideration:
COGR, AAU, APLU Joint Response Letter (August 16, 2024)
DRAFT Letter for Institutions:
Submitted via Federal eRulemaking Portal: www.regulations.gov
U.S. Department of Energy
Office of Acquisition Management
RE: Financial Assistance Regulations – Conflict of Interest and Conflict of Commitment Policy Requirements (DOE-HQ-2024-0029-0001; RIN 1991-AC18)
To Whom It May Concern:
We write in support of the August 16, 2024, letter from the Association of American Universities (AAU), the Association of Public and Land-Grant Universities (APLU), and the Council on Governmental Relations (COGR) (“Letter”) sent in response to the Department of Energy’s June 18, 2024 Notice of Proposed Rulemaking on Financial Assistance Regulations- Conflict of Interest and Conflict of Commitment Policy Requirements (89 F.R. 51460).
We are concerned about the NPRM’s requirement for a separate conflict of commitment policy for the reasons set forth in the Letter. Further, we fully support the Letter’s recommendation that the Department of Energy maintain its current Interim Conflict of Interest Policy (with the modifications suggested in the Letter), which institutions have been operating under since December 2021.
We appreciate the opportunity to provide comments on this important regulation.
Sincerely,
XXX
