Management plans manage, reduce, or eliminate actual, potential, or perceived conflicts of interest or commitment.
Management Plans: Conflict of Interest, Conflict of Commitment, and Outside Activities
Management plans developed in accordance with the UO's Conflict of Interest, Conflict of Commitment, and Outside Activities (COI-COC) Policy use a standard template. The template clarifies expectations and clearly outlines actions that are permissible given the employee's position and job duties.
Common management plan steps include requirements to:
- Disclose the conflict in presentations and publications
- Disclose the conflict to students and collaborators
- Adhere to UO acceptable use policies for space and technology
- Request permission to hire UO students or other UO employees in the outside activity who the employee supervises or advises, including a prohibition on chairing a thesis or dissertation committee if the student is also engaged in the outside activity
- Recuse oneself from actions or decisions that would impact the outside activity
- Have third-party oversight of purchases or other actions relating to the outside activity
- Meet annually with an unconflicted third party if an employee's supervisor is also engaged in the same outside activity or interest
- Disclose new intellectual property to Industry, Innovation, and Translation
Our staff drafts the management plan and receives input on the draft from the employee, their supervisor, and department leadership as needed. After the employee, their supervisor, and other needed signatories have signed the plan, the employee accepts the plan and they may begin the outside activity.
Those with existing management plans must:
- Annually submit a disclosure of their outside activities
- Report changes in their outside activities or interests before beginning a new activity or changing an existing one
- Fully comply with the steps in their management plan
Management plans remain effective until the source of the conflict no longer exists, such as when the employee's UO job duties change or their outside activities changes.
Failure to comply with a management plan may subject the investigator to discipline, up to and including termination, consistent with applicable UO policies and collective bargaining agreements.
Login to Submit an Annual Disclosure or Report a Change
Management Plans: Financial Conflict of Interest in Research
Financial conflicts of interest (FCOIs) must be managed within 60 days of a determination by the Conflict of Interest in Research Committee (COIRC) that an investigator has an FCOI. In accordance with federal regulations, the UO cannot expend funds on a sponsored project until a management plan is in place, if one is needed, and reported to the sponsor when required.
A management plan is used to manage an FCOI. Management plans developed in accordance with federal financial conflict of interest (FCOI) in research regulations and the UO's Financial Conflict of Interest in Research Policy address specific conflicts for a specific sponsored project. The plan is designed to promote transparency and objectivity in the design, conduct, and reporting of the research.
If the investigator already has a COI/COC management plan in place, the existing plan may adequately manage the conflict in the research and no additional steps may be necessary.
If the investigator does not already have a COI/COC management plan in place, our staff work with the Conflict of Interest in Research Committee (COIRC) to draft a new management plan. Once the investigator formally accepts the management plan in the Research Administration Portal and the UO reports the FCOI to the sponsor, if needed, they may expend funds on the sponsored award.
If the COIRC cannot agree to the terms of a management plan or believes a conflict cannot be managed or mitigated, the UO has the responsibility to determine the disposition of the application or award, including reassigning an investigator's responsibility on the award or not accepting the award.
Those with existing management plans must:
- Annually submit a disclosure
- Report changes in their outside activities or interests within 30 days
- Fully comply with the steps in their management plan
Management plans remain effective through the duration of the sponsored award or when the source of the conflict no longer exists, such as when the investigator's UO job duties change or their outside activities changes.
Failure to comply with a management plan may subject the investigator to discipline, up to and including termination, consistent with applicable UO policies and collective bargaining agreements.