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Organizational and Consulting Conflicts of Interest

Scope

This guidance applies to all faculty, staff and students who perform research at Arizona State University (ASU).

Background

Federal procurement requirements concerning organizational and consulting conflicts of interests (OCCI) are intended to ensure that contracting serves the public interest and the contracting process is conducted without bias or unfair advantage.

Identifying Conflicting Interests at Universities

When a university employee consults with or provides a service to a federal Agency, the agency considers that person a representative of the university as a whole. This is regardless that the individual made a private consulting arrangement. Examples of consulting or providing services may include:

  • providing scientific, engineering and technical direction;
  • serving as an advisor and providing analysis, assistance or evaluation services;
  • preparing specifications and work statements for funding opportunities;
  • having access to proprietary, confidential or sensitive data

Note: OCCI differs from personal and financial conflicts of interest that are captured by the ORIA Conflict of Interest module in the Enterprise Research Administration system (ERA).

Scenarios

Organizational conflicts may result when an individual

  • has access to information not available to others who are competing for the funding,
  • contributes to developing a work scope for an RFP and later that individual or other ASU researchers respond to the RFP, or
  • is involved in evaluating proposals from ASU or other universities.

Note: Faculty participation in federal agency peer review committees, proposal development or performance on a sponsored research, instruction, or services projects are not considered OCCIs.

Identification, Disclosure and Management

The objectives of the internal OCCI review are to identify actual or perceived conflicts, disclose them to the sponsor as appropriate, and manage, mitigate or avoid the conflicting relationship. Members of ASU’s research community are required to disclose activities that are or may be perceived to be an OCCI during the proposal development process.

If a potential OCCI is identified and is related to proposed or ongoing research at the university, research administration staff will inform the stakeholders and coordinate resolution. For questions, contact research advancement (RA) staff.

References

Office of Management and Budget “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” 2 CFR 200.318 and 2 CFR 215.42.

FAR Subparts 2.101 and 9.5 and FAR Supplements (e.g., DFARS 209.5, NFS 1809.500).