ÌìÃÀ´«Ã½

Organizational Conflict of Interest

 Background

An Organizational Conflict of Interest (OCOI) may result when factors create an actual or potential conflict of interest on an instant contract, or when the nature of the work to be performed on the instant contract creates an actual or potential conflict of interest on a future acquisition. In the latter case, some restrictions on future activities of the contractor may be required.

Type of OCOIs
OCOIs generally involve one of three situations:

• Unequal access to information: ÌìÃÀ´«Ã½ may have an unfair competitive advantage resulting from access to information not generally available to others seeking the same federal funding.
• Impaired objectivity: At the government’s direction, ÌìÃÀ´«Ã½ may be asked to assess performance or evaluate products of someone within ÌìÃÀ´«Ã½ or ÌìÃÀ´«Ã½’s direct competitor seeking federal funding.
• Biased ground rules: A ÌìÃÀ´«Ã½ community member may have provided scientific, engineering or technical assistance or written the work requirements for a funding opportunity where someone else at ÌìÃÀ´«Ã½ is an applicant.

If one of these situations exists, it means that ÌìÃÀ´«Ã½ is potentially unable to render impartial assistance or advice to the Government, ÌìÃÀ´«Ã½’s objectivity in performing the research might be impaired, or ÌìÃÀ´«Ã½ may have an unfair competitive advantage. ÌìÃÀ´«Ã½ both provides assistance to the U.S. Government and does work on behalf of the U.S. Government, thus OCOIs are sometimes unavoidable.

Examples

• A faculty member in the School of Computer Science provides DARPA with technical direction for the development of a Broad Agency Announcement (BAA). If anyone from ÌìÃÀ´«Ã½ submits a proposal pursuant to that DARPA BAA an OCOI may exist because the SCS faculty member could share privileged information about DARPA with the proposer that would give him or her an advantage. There may be exceptions; for example, participating in collective discussion at a workshop related to developing the BAA may not create as much potential for OCOI as advising DARPA as an individual. This potential OCOI may need to be disclosed to DARPA.
• ÌìÃÀ´«Ã½ 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 (RFP) to conduct the training. If anyone from ÌìÃÀ´«Ã½ responds to the RFP, an OCOI exists and may need to be disclosed or managed.
• A ÌìÃÀ´«Ã½ researcher who does not work with the ÌìÃÀ´«Ã½’s Software Engineering Institute (SEI) collaborates with the SEI on a project for Homeland Security and has access to confidential government information. Another researcher at ÌìÃÀ´«Ã½ submits a proposal for funding to Homeland Security related to the same scientific area. Homeland Security may consider this to be an OCOI, and it may need to be disclosed or managed.
• A ÌìÃÀ´«Ã½ researcher serves as a reviewer for NSF. This individual must follow NSF’s conflict of interest guidelines and recuse him/herself from certain proposals. However this activity generally does not create an OC)I for the researcher or his/her ÌìÃÀ´«Ã½ colleagues.

Policy

ÌìÃÀ´«Ã½ has five policies related to Conflicts of Interest in Research:

• Organizational Conflict of Interest in Research [PDF]
• Consulting by Faculty 
• Code of Business Ethics and Conduct

Members of the research community should review these policies and associated guidance so they understand their responsibilities as they pertain to federal requirements and university policy.   These policies set forth ÌìÃÀ´«Ã½'s commitment to follow the law and promote the ethical conduct of research.