Senate Bill 25-26-49
| Bill ID: | 25-26-49 |
| Name: | Revisions to the University of Maryland Policy on Organizational Conflicts of Interest, II-3.10(F) |
| Proposed: | 05/01/2026 |
| Sponsor: | Sarah Hughes, Assistant Director of Research Policy Compliance |
| Proposal: | In May 2025, the Office of the President and the Division of Research created and approved technical updates to the University of Maryland Policy on Organizational Conflicts of Interest (II-3.10[F]) (“the OCI Policy”). The OCI Policy is subordinate to the University of Maryland Policy on Conflict of Interest and Conflict of Commitment (II-3.10[A]) (“the COI/COC Policy”), which was significantly revised in May 2025, and technical updates to the OCI Policy were required to bring the two policies into alignment. The proposal notes that, because the changes were urgently needed, the Division of Research did not have time to complete a holistic review of the policy or consider addressing broader issues in the policy. Beginning in summer 2025, the Division of Research undertook a broader review of the policy, finding additional areas of the policy that needed substantive revision due to changes in state and federal laws, regulations, and funding agency requirements as well as process changes given the move to inTERP. The OCI Policy focuses on the terms and conditions in the Federal Acquisition Regulation (FAR) Subpart 9.5, “Organizational and Consultant Conflicts of Interest.” All individuals and all sponsored projects that are funded by an agreement that incorporates the FAR provisions are subject to these requirements. The proposal states that in discussions with key stakeholders, it was determined that the existing Purpose section of the policy did not accurately align with the government’s focus in OCI-related cases. The section and other language framing the intent of the policy was updated to note that its requirements specifically target sponsored projects that include the FAR as a clause of the agreement as well as work performed for program or procurement offices for the federal government. In addition, information on the applicability of the policy was revised to clearly state that only those who are engaged in work that incorporates the FAR subpart in its requirements are affected by the policy. The policy was also revised to address the connections between the University and the government. Information on possible review outcomes was revised to indicate that when OCIs exist, a mitigation plan will be developed and submitted to the federal contracting officer for approval. Prior language referenced a management plan, but “mitigation plan” is consistent with the language used by the federal government. Mitigation plans must be submitted to the federal contracting officer for approval, and are not finalized by the University itself. The revisions to the policy were approved by the President on April 27, 2026 on an interim basis, pending Senate review. The proposal suggests that the Research Council should be charged with this review because they currently have an existing charge on reviewing this policy related to technical updates made to the policy in May 2025: Senate Document #25-26-17, Updates to the University of Maryland Policy on Organizational Conflicts of Interest, II-3.10(F) along with Proposal to Review the Interim University of Maryland Organizational Conflicts of Interest Policy [II-3.10(F)] (Senate Document #23-24-04). The proposal shares that, based on discussions with the Office of the President regarding substantive issues that require further consideration, it would be helpful to include a charge element for the Research Council to consider whether the policy should allow the President to have a designee (by including “or designee” in the policy language) for items that require the President’s action, such as approval of a management plan. The proposal suggests that for ease of reference and streamlined recordkeeping, the Senate Executive Committee may want to consider consolidating the review under one Senate Document Number by closing item #25-26-17 and combining those charge items into a new charge for this review. This proposal is also related to Senate Document #23-24-04. |
| Active? | Yes |
| Policy: | https://policies.umd.edu/faculty/university-of-maryland-policy-on-organizational-conflicts-of-interest |
| Related Bills: |
Status
| Status: | Under Review |
| Reviewer: | Research Council |
| Received: | 2026-06-15 |
| Actions: | The Research Council will review the proposal and updated charge. |
| Status: | Complete |
| Reviewer: | Senate Executive Committee (SEC) |
| Received: | 2026-05-01 |
| Decision Date: | 2026-05-08 |
| Decision: | The SEC voted to charge the Research Council with the review of the proposal; close Senate Document #25-26-17 and Senate Document #23-24-04; and combine the charge elements for both with the charge document for Senate Document #25-26-49. |
| Actions: | The SEC will review the proposal at their May 8, 2026 meeting. |
| Next Step: | Research Council review |
| Related Files: |