Organizational Conflict of Interest (OCI)
What is an OCI?
An Organizational Conflict of Interest (OCI) is defined as a circumstance in which a University investigator, due to their work on behalf of a U.S. governmental agency, might bias judgment in a proposal for, or the conduct of, research by another investigator at the University and, therefore, provide the institution with an unfair competitive advantage on sponsored research opportunities.
An unfair competitive advantage may arise due to:
- Unequal access to information - the potential for an investigator to utilize or provide to others proprietary, confidential, or sensitive information that is not generally available to others seeking federal funding.
- Impaired objectivity - the potential for an investigator to be impartial, for example when, in their service to the agency/sponsor, they are in a position to assess their own performance, evaluate their own products, or do so for another member of the University.
- Biased ground rules - situations where an investigator has provided key specifications, technical assistance, or written work requirements for a funding opportunity where someone in the same institution is an applicant.
Potential OCI Situations
An OCI may occur when a member of the University:
- Provides a U.S. governmental agency with engineering, scientific, or technical direction;
- Serves as an advisor to a U.S. governmental agency, providing analysis, assistance, or evaluation services, or preparing specifications and work statements;
- Acts in a capacity that gives them access to proprietary data.
- Drexel adheres to regulations as set forth in Federal Acquisition Regulation (FAR) Subpart 9.5 and Uniform Guidance 200.318c(2) as a condition of funding from certain U.S. governmental agencies. OCI requirements may also be found in requests for proposal from foundations, state agencies, and private entities.
- When grants and contracts (including subcontracts) to Drexel include the requirement for disclosure of any OCI, Drexel is required to provide the sponsor with detailed information about its program for training, disclosure, review, and reporting of OCI as documented in an OCI Avoidance Plan. Each agency or sponsor may require different information, either upon submission of a funding proposal or within a "just-in-time" process prior to award activation.
- In the event a potential OCI is identified and related to proposed or ongoing research at Drexel, the Office of Research Compliance will work with OSP and the government’s contracting officer/program manager, the impacted Drexel personnel and their departments, relevant committees, and others as necessary to neutralize or mitigate the OCI.
- To ensure that the University can identify and appropriately manage and report an OCI, Drexel University investigators are required to disclose their outside activities on behalf of the U.S. government that may give rise to an OCI. Such activities may have been undertaken as an employee of Drexel or independently as a consultant or volunteer.
- These activities must be disclosed as part of Drexel’s annual and interim Conflict of Interest disclosure and as a part of your research and University FCOI disclosures
If an OCI is identified as being related to a funding proposal or ongoing research, the conflict must be managed to mitigate or remove the conflict. The applicable management measures may be outlined in the OCI Avoidance Plan that is shared with the sponsor. Common OCI management options include, but are not limited to:
- Notification by OSP of the OCI to the funding sponsor
- Recusal of the conflicted individual from certain research activities
- Application of specific data security measures to maintain confidentiality of proprietary, confidential, or sensitive data
- Review of the research/work by an independent third party.
An OCI Avoidance Template is available by request. All OCI Avoidance Plans must be finalized and approved through the Export Control team at export@drexel.edu.
Conflicts of Interest (COI) represent financial or other situations where an individual has an outside interest (e.g., equity in a company, intellectual property, consultant activity with a company) that could affect the design, conduct or reporting of their research. Also referred to as personal or individual COI.
Institutional conflicts of interest (ICOI) represent financial or other situations where the University, as an institution, has an outside interest (e.g., equity in a company doing business with the University) that could affect the design, conduct, reporting, review or oversight of research conducted by its employees or students.
Organizational conflicts of interest (OCI) represent situations where an individual's service or work on behalf of a U.S. government agency or other funding sponsor may provide the University, as an institution, an unfair competitive advantage when other University members apply for a funding opportunity with that agency or sponsor.