Management plans manage, reduce, or eliminate actual or potential conflicts 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.
Common Management Plan Steps
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.
Common management plan steps include requirements to:
- Disclose the conflict in presentations and publications
- Disclose the conflict to students and collaborators
- Recuse oneself from actions or decisions that would impact the outside activity or financial interest
- Have third-party oversight of purchases or other actions relating to the outside activity or financial interest
- Remove oneself from an informed consent process for human subjects studies, if applicable
- Remove oneself from data analysis, use a double blind data analysis method, and/or use an open science framework, if applicable
Management Plan Process
If the investigator already has a 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 management plan in place or if an existing management plan needs addition steps to manage the conflict, our staff work with the Conflict of Interest in Research Committee (COIRC) to draft a new management plan or new steps to an existing plan. For AY2024-25, the COIRC meets on the fourth Wednesday of every month. 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 investigator, 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.
Management Plan Compliance
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.