Organizational conflict of interest (OCI) assessment is a requirement of many government and some industry sponsors that fund Georgia Institute of Technology (Georgia Tech) research. The purpose of OCI assessment is to ensure objectivity in federal contracting. As a contractor, it is Georgia Tech’s intent to detect, avoid, and mitigate any OCI issues in its dealings with sponsors. The Organizational Conflict of Interest Policy provides consistency across such assessments and assurance to those sponsors who require that such a policy be in place before contracting with Georgia Tech.
An organizational conflict of interest may occur when a federal contractor has an Unfair Competitive Advantage over other potential contractors or is unable to avoid Impaired Objectivity, or the appearance of Impaired Objectivity, in the course of the contracted work. (See section 4 below for detailed definitions of Unfair Competitive Advantage and Impaired Objectivity.) In order to comply with the Federal Acquisition Regulation (FAR) Subpart 9.5 – Organizational and Consultant Conflicts of Interest, researchers or their designates submit all research proposals via the eRouting system, where they answer questions about the programmatic requirement of an OCI assessment. Proposals that may contain an OCI requirement, as well as proposals for which the researcher would like a review, move to a member of the OCI Review Committee for a more detailed analysis. Georgia Tech is committed to recognizing, avoiding and mitigating potential organizational conflicts of interest, both real and perceived, wherever possible.
OCI review results are retained by the OCI committee and communicated via the eRouting system for institutional documentation.
This policy applies to all employees conducting sponsored research at Georgia Tech.
| Unfair Competitive Advantage | Competing for work after having had access to source selection relevant information (from the sponsor or competitor’s private data) not available to all competitors or having defined the ground rules of the competition. |
| Impaired Objectivity | Evaluating one’s own products, or similar products from competitors, on behalf of the government, in which judgment could be impaired or guidance provided to the government could be biased. |
OCI Evaluation
| Submission | The initial step for submission of any proposal at Georgia Tech is an entry into the eRouting system. This system contains a series of initial screening questions for OCI. Learn more here. |
| Review | The screening questions in eRouting trigger an evaluation by the OCI Review Committee of all proposals that indicate a potential OCI or the potential appearance of an OCI. The committee’s review process typically includes, at a minimum: assessment of all relevant proposal paperwork and a search of other projects currently or recently underway for the sponsor by Georgia Tech researchers. Reviews generally take place as quickly as possible in the order in which the proposals were received, though the committee will place a greater priority on those proposals with a pending sponsor deadline. The review will be initiated within five business days of the committee’s receipt of the request, but the time frame for completion of the review will depend on its complexity. |
Faculty and Staff
Faculty and staff submitting proposals, conducting research, and supporting research operations are expected to consider the potential of organizational conflict of interest (OCI). They are to bring any concerns about possible OCI or the appearance of OCI to the attention of the Office of the Executive Vice President (EVPR), or the Georgia Tech Research Institute (GTRI), as well as to the contracting officer for the sponsor engagement. Faculty and staff should review information regarding submission timelines here. During execution of the project, researchers are to be vigilant about any developments which may introduce OCI. They must bring these to the attention of the above contracting officer so that these new developments can be disclosed, and potential mitigations considered.
Contracting Officers
When a proposal requires OCI review, the assigned contracting officer in the Georgia Tech Research Corporation or the Georgia Tech Applied Research Corporation ensures that the OCI Review Committee has evaluated the proposal and provided a recommendation. Based on that recommendation, the contracting officer is responsible for completing the necessary paperwork and certifying Georgia Tech’s compliance as required. The contracting officer is responsible for disclosing to the sponsor any OCI that emerges in the course of the work and for addressing any required mitigation actions with their counterparts in the sponsoring organization.
Office of the Executive Vice President for Research (EVPR)
The EVPR’s office is responsible for ensuring the accurate and thorough assessment of potential OCI on any given project, to the best of Georgia Tech’s ability. The Executive Vice President for Research directly appoints 1-2 members of the OCI Review Committee and delegates appointment of GTRI representatives to the director of GTRI. Other groups or offices may be asked to participate in this process at the direction of the EVPR.
Director of the Georgia Tech Research Institute (GTRI)
GTRI is designated as a University Affiliated Research Center (UARC) by the Department of Defense. A UARC is required to operate in the public interest and conduct its business in a manner befitting its special relationship with the government. To maintain the government’s trust in the integrity of the work, the GTRI Director has established a specially trained team that closely evaluates all proposals going out of GTRI. This team maintains OCI support throughout the life cycle of each GTRI project and supports the EVPR on other projects as required.
Georgia Tech Organizational Conflict of Interest (OCI) Review Committee
The OCI Review Committee works with researchers to evaluate the potential for OCI in sponsored projects, and then to plan and document avoidance or mitigation strategies if necessary and appropriate. The OCI committee also provides contracting officers in the Georgia Tech Research Corporation and the Georgia Tech Applied Research Corporation with advice on how to complete required OCI review certification or disclosure documents in sponsored proposals. Finally, the OCI review committee is available as a consulting body if researchers have questions around OCI or suspect that circumstances within their project may have altered their original analysis of real or perceived OCI.
The Georgia Tech OCI committee works diligently to ensure that noncompliance does not become an issue in the course of the award. Anyone involved in research who becomes aware of such an occurrence should immediately contact the EVPR office for correction according to the sponsor’s guidelines. Failure to disclose potential OCI issues to sponsors can cause awards to be rescinded or terminated or result in restrictions on future contracting. Actual OCI or the appearance of OCI can also be a cause for protests from competitors, creating program delays, loss of funding, and strained relations with government and industry partners. Deliberate violation of this policy constitutes research misconduct.
| Revision Date | Author | Description |
|---|---|---|
| 09/2021 | Office of the Executive Vice President for Research | New Policy |