Resolving and Managing Conflicts

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

Management Strategies to Minimize or Mitigate conflicts: 

• 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).
• Firewalls and Information Barriers (e.g., establishing strict separation between teams or departments to prevent the flow of sensitive information that could lead to a conflict).
• Recusal from Decision-Making (e.g., excluding individuals or units with potential conflicts from decision-making processes related to the conflict).

However, while some conflicts of interest cannot be entirely avoided, they often can be effectively resolved, managed or mitigated.

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 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.

At the University of Maryland, only the President is authorized to approve a COI Management Plan. The President reviews committee recommendations and decides whether to approve the proposed plans.

Mitigation Plans for Organizational Conflicts of Interest are reviewed by the VPR and provided to the sponsor for final approval.