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Proposal:
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In May 2025, the Office of the President and the Division of Research created and approved revisions to the University of Maryland Policy on Conflict of Interest and Conflict of Commitment (II-3.10[A]) (“the COI/COC Policy”) to address new federal/state laws and regulations, federal funding agency requirements, and new implementation processes that support these measures, including the launch of the University's inTERP disclosure system. The University of Maryland Policy on Organizational Conflicts of Interest (II-3.10[F]) (“the OCI Policy”) is subordinate to the COI/COC Policy, and describes many of the same processes as are used for the COI/COC Policy. The significant revisions to the COI/COC Policy created a misalignment, as well as inconsistencies and inaccuracies within the subordinate COI policies (FCOI, ICOI, and OCI). The Division of Research took steps to make technical amendments to all three subordinate COI policies to align them with the structure, format, and content of the COI/COC Policy.
The OCI Policy applies to University sponsored projects that are funded by an agreement that incorporates in its terms and conditions the Federal Acquisition Regulation (FAR) Subpart 9.5, “Organizational and Consultant Conflicts of Interest.” All individuals working with such projects are subject to the requirements of the FAR provision and of the OCI Policy. The OCI Policy articulates the University’s processes for complying with the FAR and seeks to avoid organizational conflicts of interest (OCIs) that arise because of unequal access to information, impaired objectivity, and/or biased ground rules. Technical amendments were made to the OCI Policy in order to align with the COI/COC Policy. |
