Organizational Conflict of Interest (OCI)

An Organizational Conflict of Interest (OCI) occurs when the University's organizational relationships, activities, or responsibilities could impair—or appear to impair—its objectivity in performing federally funded work or provide an unfair competitive advantage.

Unlike a personal Conflict of Interest, which involves an individual's financial or personal interests, an OCI involves the interests or activities of the University or another organizational entity participating in a project.

Many federal sponsors require institutions to identify, disclose, manage, and, when necessary, eliminate organizational conflicts of interest before an award is made.

Federal Sponsor Requirements

Certain federal agencies—including the Department of Defense (DoD), ARPA-H, and other agencies using the Federal Acquisition Regulation (FAR)—require applicants to disclose potential Organizational Conflicts of Interest during proposal submission or prior to award.

Federal requirements are intended to ensure that organizations competing for federal funding:

• maintain objectivity in performing research or other work;
• do not obtain an unfair competitive advantage during the proposal process; and
• appropriately protect proprietary, confidential, or source-selection information.

Depending on the sponsor, the University may be required to certify that no OCI exists or submit an OCI mitigation plan before an award can be made.

Common Types of Organizational Conflicts of Interest

Federal guidance generally recognizes three common categories of OCI.

Unequal Access to Information

The University obtains non-public, proprietary, confidential, or source-selection information through one activity that could provide an unfair competitive advantage in another federal procurement or funding opportunity.

Impaired Objectivity

The University is placed in a position where it must evaluate its own work, products, services, recommendations, or those of a closely related organization, creating concerns regarding impartiality.

Biased Ground Rules

The University, or one of its employees, assists a federal agency in preparing specifications, work statements, evaluation criteria, or other requirements for a future funding opportunity and later seeks to compete for that same work.

Examples

Examples of activities that may create an Organizational Conflict of Interest include:

• A faculty member assists DARPA in developing technical requirements for a future Broad Agency Announcement (BAA), and the University later submits a proposal in response to that announcement.
• A University researcher develops technical specifications or evaluation criteria for a federal agency that are incorporated into a future solicitation.
• A project team gains access to proprietary or source-selection information while supporting a federal agency and later competes for related work.
• The University is asked to independently evaluate products, services, or research that it previously developed or performed.

University Disclosure Requirements

The University's annual Disclosure of External Interests & Commitments process does not replace sponsor-specific Organizational Conflict of Interest requirements.

When required by a sponsor, investigators, key personnel, subcontractors, consultants, and other project participants may be required to complete additional Organizational Conflict of Interest disclosures during proposal preparation or award administration.

Early disclosure allows the University to determine whether an actual or potential OCI exists and whether mitigation or sponsor notification is required.

Organizational Conflict of Interest Review Process

When an OCI requirement applies, the Office of Sponsored Programs and the Office of Research Security work together to:

• review the proposed project and sponsor requirements;
• identify actual or potential Organizational Conflicts of Interest;
• evaluate the significance of the conflict;
• determine whether the conflict can be avoided, neutralized, or mitigated; and
• prepare sponsor certifications or mitigation plans when required.

Managing Organizational Conflicts of Interest

When an Organizational Conflict of Interest is identified, the University will determine the most appropriate management strategy.

Avoid

Eliminate the conflict by modifying project personnel, removing affected work, or declining activities that create the conflict.

Neutralize

Implement measures that remove the unfair competitive advantage or eliminate concerns regarding impaired objectivity.

Mitigate

Develop and implement a management plan that reduces the conflict to an acceptable level while protecting the integrity of the research and the federal procurement process.

Examples of OCI Management Strategies

Management measures may include:

• Sponsor notification and approval
• Recusal of conflicted individuals
• Independent technical review
• Firewalls and restricted access to sensitive information
• Separate project personnel or reporting structures
• Protection of proprietary or source-selection information
• Other sponsor-approved mitigation measures

Related University Resources

• Disclosure of External Interests & Commitments
• Conflict of Interest
• Conflict of Commitment
• Export Controls

Frequently Asked Questions

Organization Conflict of Interest FAQs

Need Assistance?

Questions regarding Organizational Conflicts of Interest should be raised as early as possible during proposal development or whenever circumstances change during an active award.

Office of Sponsored Programs (OSP)

Provides assistance with sponsor proposal requirements, certifications, contract terms, and sponsor communications related to Organizational Conflicts of Interest.

Office of Research Security (ORS)

Provides assistance with Organizational Conflict of Interest reviews, sponsor disclosure requirements, mitigation planning, research security considerations, and coordination with other University compliance offices.