Carnegie Mellon University
Organizational Conflict of Interest

Organizational Conflict of Interest

 Background

An Organizational Conflict of Interest (OCI) 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 OCIs
OCIs generally involve one of three situations:

  • Unequal access to information: CMU 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, CMU may be asked to assess performance or evaluate products of someone within CMU or CMU’s direct competitor seeking federal funding.
  • Biased ground rules: A CMU community member may have provided scientific, engineering or technical assistance or written the work requirements for a funding opportunity where someone else at CMU is an applicant.

If one of these situations exists, it means that CMU is potentially unable to render impartial assistance or advice to the Government, CMU’s objectivity in performing the research might be impaired, or CMU may have an unfair competitive advantage. CMU both provides assistance to the U.S. Government and does work on behalf of the U.S. Government, thus OCIs 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 CMU submits a proposal pursuant to that DARPA BAA an organizational conflict of interest 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 organizational conflict as advising DARPA as an individual. This potential organizational conflict may need to be disclosed to DARPA.
  • CMU 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 CMU responds to the RFP, an organizational conflict of interest exists and may need to be disclosed or managed.
  • A CMU researcher who does not work with the CMU’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 CMU submits a proposal for funding to Homeland Security related to the same scientific area. Homeland Security may consider this to be an organizational conflict of interest, and it may need to be disclosed or managed.
  • A CMU 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 OCI for the researcher or his/her CMU colleagues.

Policy

CMU has three policies related to Conflicts of Interest in Research:

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 CMU's commitment to follow the law and promote the ethical conduct of research.  Details of the COI policy and process are outlined in the COI Guidelines [PDF] document.

The Office of the Vice Provost for Research and the Office for Research Integrity and Compliance (ORIC) are responsible for compliance with financial conflict of interest regulations and policy.