Management plans manage, reduce, or eliminate actual, potential, or perceived conflicts of interest or commitment.
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:
Our staff drafts the management plan in coordination with Industry, Innovation, and Translation to ensure proper handling of intellectual property. Our staff then shares the draft with the employee for their input before sharing the draft with the employee's supervisor and department leadership, as needed. After the employee, their supervisor, and other needed signatories have agreed to and signed the management plan, the employee accepts the plan in the Research Administration Portal (link prompts user to enter their Duck ID) and they may begin the outside activity.
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.
Those with existing management plans must:
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.
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.
In addition to the common management plan steps listed above, common steps for plans under the FCOI policy include:
Common management plan steps include requirements to:
If the investigator already has a COI/COC management plan (described above) 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. Industry, Innovation, and Translation also reviews the plan to ensure proper handling of intellectual property. The investigator and their supervisor or department leadership have an opportunity to review the plan and ask questions. After the employee, their supervisor, and other needed signatories have agreed to and signed the management plan, the employee accepts the plan in the Research Administration Portal (link prompts user to enter their Duck ID). The UO may be required to notify the sponsor of the conflict and the steps undertaken to manage it.
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:
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.
