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Organizational Conflict of Interest (OCI) reviews are assessments required by sponsors for certain funded research or contractual scenarios to determine any overlap in the University’s activities. An Organizational COI review is only required in sponsored research situations under the following parameters:

Uniform Guidance:  In accordance with 200.318(c)(2), the University maintains a code with a process to address certain situations where the University would be unable to be impartial in a procurement action involving a related organization.  These requests are generated directly by OSR to the COI Office.

Contract Requirement:  Where the sponsoring organization requires a review to determine if the University has a related entity or has current or prior work which creates any:

    • Impartial assistance
    • Impaired objectivity
    • Unfair competitive advantage

These contract requirement reviews are completed by request of the Office of Sponsored Research, either at proposal or upon award. Certification or response is returned to OSR as needed.

The process used by the COI Program includes a comparison of the proposed project with the following information:

  • any currently funded or recently completed projects and pending proposals at the University supported by the Sponsor,
  • all currently funded or recently completed projects and pending proposals of all investigators listed on the proposal, regardless of their source of funding, and
  • a search of all currently funded or recently completed University projects and pending proposals containing pertinent key project words.

This three-way comparison is completed to determine if there is any possible overlap of technical assistance or project goals within the University with the proposal itself.


NOTE:  If an OCI review is required at proposal, the COI office needs five business days to complete a review.  The IPF should be submitted to OSR no later than 7 business days prior to the submission deadline to ensure a timely review.