When is a management plan needed?
If it is determined that a conflict exists or appears to exist, a management plan will be established. The conflicted investigator is involved in the development of the plan.
What does a management plan require?
Examples of mechanisms that are used to manage conflicts include:
- Public disclosure of SFIs;
- Monitoring of research by independent reviewers;
- Modification of the research plan; or
- Change of personnel.
Every situation is unique. Every management plan is tailored to the specifics of the research activity and conflict.
Who will know that there is a management plan in place?
In some instances the funding agency will be notified that a management plan is in place. Conflicted Investigators are required to notify other members of the research team that they have a financial conflict of interest. Department administrators will have access via SPARCS COI to the information that a management plan is in place, but will not have access to the details of the plan via SPARCS unless the individual plan calls for them to be given detailed information. If the plan involves financial oversight of a subcontract or consultant, the Sponsored Projects Accounting team may have access to the plan so that they can confirm the correct personnel have approved spending on that subcontract.
Is the management plan monitored?
Yes. Each plan approved within SPARCS COI has an assigned COI Monitor, who will provide a monitoring update to ORIC at the frequency written into the individual plan. Older plans that predate SPARCS do not have a specific assigned monitor; ORIC monitors these older plans approximately yearly.