Guidance for Conflict of Interest Management Plans
In some instances it is necessary to manage, mitigate, reduce or eliminate FCOIs. CMU works with Investigators to explore whether there are structures that would allow research to continue by implementing a COI management plan.
If a management plan is required, ORIC will develop a written plan in consultation with you and your department head. This plan describes the research and your company’s involvement with it, as well as the measures that will be taken to minimize conflict of interest potential.
Examples of mechanisms that are used to avoid or manage conflicts include:
▪ Public disclosure of SFIs (e.g., when presenting or publishing research);
▪ Monitoring of research by independent reviewers;
▪ Modification of the research plan;
▪ Change of personnel or personnel responsibilities;
▪ Divestment of the financial interest;
▪ Severance of relationships that create the conflict (e.g., consulting);
▪ For research projects involving human subjects research, disclosure of FCOIs directly to human
participants; or
▪ Written disclosure of the conflict to all individuals working on the research project.
ORIC will communicate its determination regarding a management plan to the Investigator in writing. The Investigator may not commence or participate in the research until the Investigator agrees to and complies with a management plan imposed to manage a FCOI. Once agreed to, ORIC works with departments to monitor compliance with the management plan. Management plans are sometimes updated to reflect changes in research personnel, financial interests or other factors.
ORIC does not typically write general management plans covering current and future collaborations with conflicted entities. Each new collaboration will be reviewed on a case by case basis and will have its own plan.