Management Plans

The Conflict of Interest (COI) Office with support from the Objectivity in Research (OIR) Committee will determine whether a covered individual has a financial conflict of interest (FCOI) related to their research activities.

If a management plan is required to manage, reduce, or eliminate a conflict of interest related to research, the COI Official and the Office of Research Support and Compliance will develop a management plan in cooperation with the covered individual to address the conflict of interest. The input and final approval of the OIR Committee may be required for this process. If the covered individual is involved in research involving human subjects, the Institutional Review Board will be notified of the FCOI and will have opportunity to require additional management strategies to address the rights and protection of human subjects participating in the research.

Examples of conditions or restrictions that might be imposed to manage FCOI include, but are not limited to:

  • Public disclosure of the FCOI (e.g. when presenting or publishing the research);
  • Disclosure of FCOI directly to participants in human subjects research;
  • Appointment of an independent monitor capable of taking measure to protect the design, conduct, and reporting of the research against bias resulting from FCOI;
  • Change of personnel or personnel responsibilities in certain aspects of the research in order to reduce the potential of research bias;
  • Other actions that may reduce or eliminate the FCOI

All investigators conducting research under a FCOI management plan must meet annually with their department chair or direct supervisor to review their compliance with the requirements of the management plan. Resources for completing the annual FCOI compliance review are provided here:

When a FCOI management plan has been implemented for a UT investigator, the COI Office will work with the investigator to identify all current research activity that is related to the investigator’s significant financial interest and will report the managed FCOI as required by agencies that fund the research. The Office of Sponsored Projects and the Office of Industry Engagement will contact the COI Office for FCOI project review whenever new awards or sponsored research agreements involving the investigator are received.

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