Compliance During Uncertainty: October 2026 Navigating the Storm

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Discussion Prompts:

Biosafety: How is your institution planning for implementation of the United States Government Policy for Stopping High‑Risk Life Sciences Research and NIH Biosafety Policies
•How are you identifying additional protocols that will require review under the policies?
•How do you plan on handling screening for International Research of Concern?
•Does your institution plan on adding additional resources to IBC or biosafety office?
•Do you anticipate that there may be types of research activities that your institution will pull back?

Conflict of Interest: Have you made any changes to your conflict of interest (COI) and conflict of commitment (COC) policies in anticipation of the Department of Energy's (DOE) new COI/COC rule being included in NOFOs.
•Are you applying any changes only to DOE awards?
•What type of COC review process does your institution currently use?
•Do you plan on making any changes to this process?
•How are you addressing Organizational COI review requirements?

Shouldering the Compliance Burden: Are there any areas in which your compliance burden has lightened? But, seriously, all joking aside, how are your compliance units handling all the additional compliance requirements coming out from federal agencies?
•Do you have any hope of additional staffing or resources?
•How are you communicating with your institution's leadership about increased responsibilities?

Assessing Compliance Risk:
How is your institution evaluating the risk levels associated with various compliance issues?
•Do you have an institutional paradigm for risk evaluation and ranking? •
•How is your institution establishing its risk tolerance level?
•What compliance risks are you ranking highest?
•What types of risk mitigation are you engaging in?