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Organizational Conflict of Interest (OCI)
What is an OCI?
An Organizational Conflict of Interest (OCI) is defined as a circumstance in which a University investigator, due to their work on behalf of a U.S. governmental agency, might bias judgment in a proposal for, or the conduct of, research by another investigator at the University and, therefore, provide the institution with an unfair competitive advantage on sponsored research opportunities.
An unfair competitive advantage may arise due to:
- Unequal access to information - the potential for an investigator to utilize or provide to others proprietary, confidential, or sensitive information that is not generally available to others seeking federal funding.
- Impaired objectivity - the potential for an investigator to be impartial, for example when, in their service to the agency/sponsor, they are in a position to assess their own performance, evaluate their own products, or do so for another member of the University.
- Biased ground rules - situations where an investigator has provided key specifications, technical assistance, or written work requirements for a funding opportunity where someone in the same institution is an applicant.
Potential OCI Situations
An OCI may occur when a member of the University:
- Provides a U.S. governmental agency with engineering, scientific, or technical direction;
- Serves as an advisor to a U.S. governmental agency, providing analysis, assistance, or evaluation services, or preparing specifications and work statements;
- Acts in a capacity that gives them access to proprietary data.
- A faculty member in the College of Engineering provides DARPA with technical direction for the development of a Broad Agency Announcement (BAA).
- A U-M faculty member develops a detailed model plan for the scientific and technical training of staff at the Air Force Research Laboratory. The Laboratory adopts the curriculum and incorporates it into a request for proposal to conduct the training.
- U-M researcher collaborates on a project for Homeland Security and has access to confidential government information.
About the OCI Compliance Program
U-M adheres to OCI-related regulations, such as Federal Acquisition Regulation (FAR) Subpart 9.5 and Uniform Guidance 200.318c(2) as a condition of funding from certain U.S. governmental agencies. OCI requirements may also be found in requests for proposal from foundations, state agencies, and private entities.
When grants and contracts (including subcontracts) to U-M include the requirement for disclosure of any OCI, U-M is required to provide the sponsor with detailed information about its program for training, disclosure, review, and reporting of OCI as documented in an OCI Avoidance Plan. Each agency or sponsor may require different information, either upon submission of a funding proposal or within a "just-in-time" process prior to award activation.
In the event a potential OCI is identified and related to proposed or ongoing research at U-M, the Office of Research and Sponsored Projects (ORSP) will work with the government’s contracting officer/program manager, the impacted U-M personnel and their departments, U-M’s COI committees, and others as necessary to neutralize or mitigate the OCI.
OCI Disclosure and Management
To ensure that the University can identify and appropriately manage and report an OCI, U-M investigators are required to disclose their outside activities on behalf of the U.S. government that may give rise to an OCI. Such activities may have been undertaken as an employee of U-M or independently as a consultant or volunteer.
These activities must be disclosed in M-Inform as part of U-M’s annual outside activity disclosure and certification process.
If an OCI is identified as being related to a funding proposal or ongoing research, the conflict must be managed to mitigate or remove the conflict. The applicable management measures may be outlined in the OCI Avoidance Plan that is shared with the sponsor. Common OCI management options include, but are not limited to:
- Notification by ORSP of the OCI to the funding sponsor
- Recusal of the conflicted individual from certain research activities
- Application of specific data security measures to maintain confidentiality of proprietary, confidential, or sensitive data
- Review of the research/work by an independent third party.
Conflicts of Interest (COI) represent financial or other situations where an individual has an outside interest (e.g., equity in a company, intellectual property, consultant activity with a company) that could affect the design, conduct or reporting of their research. Also refered to as personal or individual COI.
Institutional conflicts of interest (ICOI) represent financial or other situations where the University, as an institution, has an outside interest (e.g., equity in a company doing business with the University) that could affect the design, conduct, reporting, review or oversight of research conducted by its employees or students.
Organizational conflicts of interest (OCI) represent situations where an individual's service or work on behalf of a U.S. government agency or other funding sponsor may provide the University, as an institution, an unfair competitive advantage when other University members apply for a funding opportunity with that agency or sponsor.
References and Resources
Who do I contact for help?
For OCI questions related to funding proposals, contact your ORSP project representative.
For questions about outside interest disclosure, email COI.Support@umich.edu.
For questions about using M-Inform, the University's Outside Interest Disclosure system, contact the ITS Service Center by phone, email, or online service request.