Management plans manage, reduce, or eliminate actual, potential, or perceived conflicts of interest or commitment.
Management Plans Under the Conflict of Interest, Conflict of Commitment, and Outside Activities Policy
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
Common management plan steps include requirements to:
- Disclose the conflict in presentations and publications
- Disclose the conflict to students and collaborators
- Adhere to UO acceptable use policies for space and technology
- Request permission to hire UO students or other UO employees in the outside activity who the employee supervises or advises, including a prohibition on chairing a thesis or dissertation committee if the student is also engaged in the outside activity
- Recuse oneself from actions or decisions that would impact the outside activity
- Have third-party oversight of purchases or other actions relating to the outside activity
- Meet annually with an unconflicted third party if an employee's supervisor is also engaged in the same outside activity or interest
- Disclose new intellectual property to Industry, Innovation, and Translation
Management Plan Process
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 Plan Compliance
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:
- Annually submit a disclosure of their outside activities
- Report changes in their outside activities or interests before beginning a new activity or changing an existing one
- Fully comply with the steps in their management plan
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.
Login to Submit an Annual Disclosure or Report a Change
Management Plans Under the Financial Conflict of Interest in Research Policy
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.
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:
- 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 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 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 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.
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.