Conflict of Interest Management Plans

Overview

When the University determines that a significant financial interest or outside activity creates an actual, potential, or perceived conflict of interest, a Management Plan may be developed to reduce, eliminate, or appropriately manage the conflict while allowing the research or other activity to proceed.

Management Plans are developed on a case-by-case basis and are tailored to the specific research activity, financial interest, and potential risks involved.

Common Management Strategies

Depending on the circumstances, a Management Plan may include one or more requirements such as:

• Public disclosure of financial interests in publications or presentations
• Disclosure of conflicts to research participants, when appropriate
• Independent oversight or monitoring
• Modification of research responsibilities
• Restrictions on procurement or contracting decisions
• Additional institutional oversight
• Periodic reporting or certification
• Restrictions on student supervision
• Compliance with intellectual property requirements
• Other conditions necessary to protect research integrity

Not every Management Plan includes every condition.

Responsibilities

Investigators with an approved Management Plan are responsible for:

• Complying with all Management Plan requirements.
• Updating their University disclosures as required.
• Reporting new financial interests within 30 days.
• Informing ORS when circumstances change.
• Completing required training.

Failure to comply with a Management Plan may result in additional institutional actions.