When is a Conflict Management Plan (“CMP”) required?
There are three general areas in which a conflict management plan (CMP) may be required:
- Conflict of Commitment
- Individual Conflict of Interest in Research
- Commercializing University discoveries, inventions, or patents (including startup companies)
A conflict of commitment will be identified and managed by
the employee’s direct report. The Office of Research will be involved
in the development and implementation of CMPs as they relate to
research and/or startup companies where appropriate.
Below are the CMP templates that the University of Cincinnati Office of Research utilizes.
Conflict of Commitment and CMP
- Individual Conflict of Interest
- Commercializing University Discoveries
If employees are consulting on projects unrelated to their
University employment, there is likely no conflict of commitment and no
CMP is required. The department head and dean, however, still must
ensure that there is no conflict of commitment with their UC duties.
Any conflict of commitment issue must be resolved by the employee’s
direct report or the respective Dean. Conflicts of Interest in Research and CMPs in the Office of Research
a. Individual Conflict of Interest: A CMP may be required by
the Institution’s designated official in the Office of Research and/or
the Conflict of Interest Committee if it is determined that a conflict
of interest is identified (real or perceived) that relates to any
outside activity(s) and the employee’s university research. A potential
conflict of interest may be identified by the employee’s direct report
or the Office of Research. The Institution’s designated official will
assist employees in the development of a CMP. The Conflict of Interest
Committee will review the CMP and it must be reviewed and approved by
the Vice President for Research. Once approved by the VP for Research,
the CMP is valid for one year unless otherwise indicated. See Conflict
of Interest on Externally Funded Projects policy of the Office of
Research for additional information.
b. Commercializing of discoveries, inventions, patents,
startup companies: Any faculty, staff, or student employee who is the
creator of a discovery or invention that is owned by the University of
Cincinnati and who desires to acquire equity or other financial
interest in a firm, corporation, or other association to which the
University of Cincinnati has or will have assigned, licensed,
transferred or sold its interests in the discovery or invention made or
created by that employee or in a patent issued to that employee, is
required to create and submit a CMP per board rule 10-17-09. This board
rule creates an exception to Chapter 102 and sections 2921.42 and
2921.43 of the Revised Code. The Conflict of Interest Committee will
review the CMP and it must be reviewed and approved by the Vice
President for Research. Once approved by the VP for Research, the CMP
is valid for one year unless otherwise indicated.
For additional information,
please consult the OAR Guidance
document or contact your Department Chair, Dean, or the Conflict of Interest Officer. (link to OAR Guidance)