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Conflicts—whether real or perceived— can undermine the integrity of UMD research and sponsored programs.

Management Strategies to Minimize Research COIs: 

  • Eliminate the incentive bias (e.g., give up equity, step down from consultancy)
  • Reduce incentive bias to an acceptably low level (e.g., restrict equity)
  • Manage the consequences of the incentive bias (e.g., independent monitoring via a management plan).
  • However, while some conflicts of interest cannot be entirely avoided, they often can be effectively resolved or managed.

To ensure this objectivity, members of the UMD community are expected to:

  • Prevent individual or institutional conflicts of interest/commitment in their assigned duties for the University;
  • Disclose potential conflicts of interest and adhere to any requirements created to manage or eliminate any conflicts of interest;
  • Ensure personal relationships do not interfere with objective judgment in decisions affecting University employment or the academic progress of a Community Member or a student; and
  • Ensure their assigned duties for the University receive their full effort, attention, and commitment.

IMPORTANT: Before writing a management plan, we strongly recommend that you contact the COI office to talk with the COI administrator and/or COI Chair about your particular situation and what documents must be submitted with your disclosure.

Management Plans must describe the means by which the conflict or potential conflict can be eliminated, reduced, or managed.

Examples of when a Management Plan (MP) and oversight official are required.

  • Familial relationship
  • UMD awards that include a prime-sub relationship with the company in which you have a relationship (see management plan below)
  • MIPS awards
  • Consulting and/or gifts when there is another relationship (award, gift, agreement) with the entity

Example Management Plan may look like this:

  • The Oversight Official will meet with the researcher, the COI Chair and/or Administrator(s), and administrators in the Department to review roles, responsibilities, and expectations regarding the review.
  • The Oversight Official will meet (with COI Committee members as needed) annually with students and employees on the project independently from the researcher to brief them on the COI Management Plan and have the group sign an attestation to that effect.
  • The Oversight Official may be required to initiate, authorize, and approve subaward request forms and invoices and/or sign off on monthly accounting of spending on all affected awards.
  • The Oversight Official will meet the researcher at least once a year to review Annual Reports and will submit reports to the COI Committee within 4 weeks of the annual review meeting to remain in compliance with this Management Plan.

The management plan resources below may be used as a starting point for developing a plan:

President: Approve (or not) proposed COI management plans

  • Review committee recommendations and approve (or not) proposed COI management plans.
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