Upon review of the investigator's sponsored research and significant financial interest (SFI) declaration, Research Compliance Services (RCS) makes a determination about whether or not there is an actual, potential, or apparent conflict of interest. When conflict(s) are identified, RCS will draft a management plan which is then reviewed by the Conflict of Interest in Research Committee (COIRC).
The purpose of a management plan is to manage, reduce, or eliminate any actual, potential or perceived financial conflict of interest in research (FCOIR) as it relates to a specific sponsored project and the investigator’s institutional responsibilities. The plan contains a series of steps designed to promote transparency and objectivity in the design, conduct, and reporting of the research.
The COIRC will review the draft and approve a finalized management plan. The plan is sent to the investigator for review and acceptance. The investigator may request further considerations for the committee regarding plan steps. Once accepted, the management plan is routed to the appropriate Dean, Department Head and/or Center/Institute Director for approval. If the investigator, appropriate signatory officials, and the COIRC cannot agree to the terms of a management plan, the institution has the responsibility to determine the disposition of the application or award, including reassigning an investigators responsibility on the award or not accepting the award.
FCOIRs must be managed within 60 days of submission of the declaration. Prior to the University's expenditure of any funds associated with a specific sponsored project, the sponsored project's FCOI investigators' declarations must be reviewed and, if necessary, managed. In addition, all required sponsor reporting of any conflicts of interest must be completed. A Banner Index for the sponsored activity cannot be established until these actions are complete.
Compliance with the approved management plan is required and the plan remains in effect until formally closed by RCS. If a newly acquired or identified SFI is declared by an investigator, the SFI will be reviewed to determine if any revision of the management plan is required. RCS considers closing management plans when the SFI changes or no longer exists; when the investigator's institutional responsibilities change; and/or when the sponsored project ends. In some cases a management plan may remain in effect beyond the life of a sponsored project.