In December 2020, the U.S. Government Accountability Office (GAO) published report GAO–21–130, Federal Research: Agencies Need to Enhance Policies to Address Foreign Influence. This report included two recommendations for NASA that pertained to (1) updating NASA's conflict of interest policy to include a definition of non-financial conflicts, such as conflicts of commitment, and (2) documenting procedures, roles, and responsibilities for addressing and enforcing failures to disclose required information. In response to GAO–21–130, NASA published a proposed conflict of interest and conflict of commitment policy in the Federal Register in January 2023 (88 FR 5930, pages 5930–5932, January 30, 2023). After reviewing public comments and feedback, NASA revised the proposed policy to only address financial conflicts of interest.
The revised policy is designed to standardize NASA's conflict to interest disclosure requirements with those of other Federal research funding agencies. In summary, the policy requires NASA grant and cooperative agreement recipients to maintain and enforce a conflict of interest policy that requires the disclosure of significant financial interests to an authorized official prior to application submission. Prior to the expenditure of grant or cooperative agreement funds, the institution shall review disclosed significant financial interests, determine if a conflict of interest exists, and determine what conditions or restrictions, if any, should be imposed to manage, reduce, or eliminate such conflict of interest. Institutions shall notify NASA of any conflict of interest that cannot be managed, reduced, or eliminated in accordance with the institution's policy.