Guidance for Conflict Managers: Implementing and Monitoring COI Management Plans

Purpose

This guidance outlines the responsibilities of individuals designated as Conflict Managers for approved conflict of interest (COI) Management Plans.

Conflict Managers play a key role in ensuring that approved safeguards are implemented effectively and followed consistently within departmental operations.

Role of the Conflict Manager

The Conflict Manager is responsible for:

  • implementing the approved COI Management Plan in practice;
  • monitoring ongoing compliance with required safeguards; and
  • ensuring that the plan functions effectively within the department.

Because department heads and supervisors are familiar with departmental operations, student involvement, and project oversight, they are typically best positioned to translate management plan requirements into practical, workable processes.

RIC provides the framework; the Conflict Manager ensures that the plan is carried out appropriately.

Core Responsibilities

1. Understand the Management Plan

  • Review the approved COI Management Plan in full.
  • Ensure you understand all:
    • safeguards,
    • restrictions,
    • disclosure requirements, and
    • oversight conditions.
  • Contact RIC if any part of the plan is unclear.

2. Determine How the Plan Will Be Implemented

  • Identify how each requirement of the plan will be carried out within departmental workflows.
  • Work with the Researcher to establish practical implementation steps.

This may include:

  • how recusal from decisions will occur and be documented;
  • how student or trainee involvement will be protected;
  • how purchasing, vendor selection, or financial oversight will be handled;
  • how data access, analysis, or reporting will be monitored;
  • how activities conducted for USU and external entities will remain separate.

The Conflict Manager implements the plan but does not modify it. If challenges arise, consult RIC before making any changes.

3. Implement Safeguards Related to Financial Transactions (if applicable)

When a management plan involves financial arrangements (e.g., donations or external funding):

  • ensure funds are not controlled or influenced by the conflicted individual;
  • confirm that a non-conflicted administrator oversees receipt, monitoring, and use of funds;
  • adjust workflows as needed to ensure:
    • separation of duties,
    • appropriate approvals, and
    • documentation of all related transactions.

4. Coordinate With Relevant Offices

Some safeguards may require coordination with other units, such as:

  • School of Graduate Studies (student supervision and assignments)
  • Sponsored Programs (award management and compliance)
  • Technology Transfer Services or other administrative offices

Engage relevant offices as needed to ensure requirements are implemented effectively.

5. Maintain Documentation

Maintain brief records demonstrating implementation and oversight of the management plan.

Examples include:

  • documentation of recusal or delegated decision-making;
  • records of oversight activities (e.g., independent review or co-signatures);
  • confirmation of separation between University and external work;
  • summaries of compliance check-ins or monitoring discussions.

Documentation supports institutional oversight, sponsor requirements, and potential audits or reviews.

6. Monitor Ongoing Compliance

  • Periodically review whether safeguards are being followed.
  • Conduct check-ins with the Researcher and, when applicable:
    • review relevant activities, decisions, or documentation;
    • ensure safeguards remain effective.

Monitoring should be proportionate to the level of risk associated with the conflict.

7. Report Concerns or Changes

Notify RIC promptly if:

  • there are concerns about noncompliance;
  • safeguards are not functioning as intended;
  • circumstances change (e.g., new outside activities, role changes); or
  • unclear or complex situations arise.

Both the Conflict Manager and the Researcher share responsibility for timely reporting.

8. Complete Required Reports

Conflict Managers are responsible for completing periodic reports (typically annually), which may include:

  • confirmation of compliance with the management plan;
  • summary of monitoring activities;
  • identification of any issues or concerns; and
  • recommendations regarding continuation or modification of the plan.

9. Maintain Objectivity and Confidentiality

  • Act objectively and avoid conflicts related to your oversight role.
  • Maintain appropriate confidentiality when handling information related to the COI and the management plan.
  • Share information only as required for compliance or institutional purposes.

Key Principles

  • COI Management Plans are designed to enable activities to continue with appropriate safeguards, not to restrict them unnecessarily.
  • The goal is to prevent bias, protect research integrity, and maintain public trust.
    • Effective management depends on clear implementation, consistent monitoring, and timely communication with RIC.

Support

RIC is available to:

  • clarify management plan requirements;
  • assist with implementation challenges; and
  • provide guidance in complex or evolving situations.

Closing Note

Conflict Managers play a critical role in ensuring that conflicts are managed appropriately and transparently. Your oversight helps protect research integrity, students and trainees, institutional decision-making, and public trust.