Organizational Conflicts of Interest (OCI)

The University is responsible for identifying potential Organizational Conflicts of Interest (OCI) described in Subpart 9.5 of the Federal Acquisition Regulation and in University Policy RI04 (formerly Policy 11-01-08) that may provide an employee and/or another member of the University with an unfair competitive advantage in applying for federal funding or that could appear to bias its judgment.  Failure to address OCIs may adversely affect the University's ability to compete for certain federal funding.

An OCI may occur, for example, if a member of the University community provides advice, scientific, engineering or technical direction to the federal government, prepares the specifications or statement of work for a federal funding opportunity, or evaluates the work performed by another member of the University under a federal contract. Work performed on a panel to evaluate applications for research funding submitted to the federal government does not give rise to an OCI.

Examples of Potential OCIs

Biased Ground Rules

This type of OCI arises when a member of the University provides advice, scientific, engineering or technical direction to the federal government or prepares the specifications or statement of work for a federal funding opportunity and the University then applies for that funding. The conflict of interest concern is that the ground rules established for this funding opportunity may have been drafted in a way that favors the University’s capabilities.

Impaired Objectivity

This type of OCI occurs when the University of Pittsburgh either evaluates itself by reviewing the work performed by a member of the University under a government contract or when it reviews the activities of other entities that are competing with the University for federal funding. In this case, the nature of the conflict of interest concern is that the University’s ability to render impartial assistance or advice under the contract may be impaired.

Unequal Access to Information

This type of OCI arises when a member of the University has access to budgets, statements of work, evaluation criteria or other proprietary nonpublic information acquired, for example, through work performed under one federal contract that provides the University with an unfair competitive advantage in applying for another federal funding opportunity.

Disclosure

All members of the University community must disclose activities they perform as employees of the University and/or in their personal capacity as independent consultants or otherwise that may give rise to OCIs.  The COI disclosure process provides an opportunity for personnel to disclose this information.  

Assistance

Investigators should contact the COI Office as soon as they become aware of the University's obligation to comply with OCI regulations regarding federal funding proposals.  The COI Office and COI Commitee will work with individuals in developing written plans to eliminate or manage any OCIs identified. 

For additional assistance, please contact the COI Office by email.