Finalization and Assurance of a Management Plan

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At the conclusion of the meeting, the Committee will discuss the final Management Plan with the Investigator, Department Head, Dean, and relevant research Center/Institute Director (if any), to make sure all parties understand their obligations under the plan. The Management Plan will specify the individual(s) responsible for overseeing the Investigator’s adherence with all provisions of the Management Plan.  This responsibility will be assigned to Investigator’s Department Head and Dean, and/or research Institute/Center Director, depending on the nature of the Investigator’s appointment and responsibilities.

All parties will assure adherence to the plan by logging on to E-PCS and signing the Management Plan electronically. At that point, the Investigator’s FCOIR is considered to be managed. 

As long as the Investigator adheres to the elements of the Management Plan, no further action is required.  Management Plans will remain in effect as long as the nature of the Significant Financial Interest remains unchanged, the institutional responsibilities remain unchanged and the sponsored project is active.

Review of all of an Investigator’s SFIs, assurance and implementation of a Management Plan, and any required sponsor reporting of all conflicts of interest in research identified for a specific sponsored project must be completed prior to the University’s expenditure of any funds for that sponsored project. 

Please note:  A Banner Index for the sponsored activity cannot be established until all indicated Investigators’ declared SFI have been reviewed and, if an FCOIR is determined to exist, the FCOIR has been managed and reported to the sponsor, as required by sponsor regulations.

Alternatively, if a newly acquired or identified SFI is declared by an Investigator, the SFI will be reviewed to determine if an FCOIR exists and, if an FCOIR is determined, the FCOIR must be managed within 60 days of submission of the new Declaration.  If a Management Plan cannot be assured and implemented within this 60 day deadline, the Designated Institutional Official has designated authority take any necessary mitigation steps to ensure research is unfettered until a Management Plan can be finalized.