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Management Plans

Management plans are designed to facilitate transparency and necessary separation between an employee's personal activities and his/her university responsibilities in order to avoid the appearance of impropriety in university decision-making or research.  A management plan is developed when there is a potential overlap between an individual's external relationships or interests and their primary institutional responsibilities.  The Plan outlines and implements measures to actively reduce, mitigate or eliminate an actual, potential or perceived conflict of interest.  Management plans offer protection to both employees and the institution because they demonstrate a commitment to USA, integrity, transparency, and a mechanism for monitoring. Management plans are a collaboration between the employee and supervisor, and are documented in the COI Risk Manager application, linked to the employee’s annual disclosure form.

Process for Initiating a Management Plan

• If it is determined that a disclosed activity or interest poses, or appears to pose, a conflict of interest in the workplace, the employee and their respective supervisor will work to develop a written management plan.
• Management plan actions may include:  documentation of disclosure, strategies to eliminate the conflictual elements of the activity, recusal from USA discussions or decision-making that may involve one’s activity, disclosure of one’s activity to their colleagues, and/or prohibition of the activity. 
• The proposed plan will be forwarded to the respective college dean and/or vice-president for review and approval.  All research-related conflicts of interest are routed to the Office of Research Compliance and Assurance for review.   
• An employee’s conflict of interest disclosures and any existing management plans will be reviewed at least annually, or as needed, by the employee’s supervisor, the respective Dean and/or Vice President.  Additionally, research-related management plans are reviewed by a three member management team as overseen by the Office of Research Compliance and Assurance.

Management Plan Templates

The Management Plan templates provided below should be used as a starting point for developing a management plan:

• External Entity Related to Research – For faculty with interests in an external entity that sponsors research or testing with the university
• External Entity Related to University Duties – For faculty or managerial-administrative employees with interests in an external entity related to university duties
• Familial Relationship in Sponsored Research – For situations when there is a COI due to a family member working on a sponsored project together
• Management Plan for Human Subjects Research
• Generic (non-Research) - For COI scenarios that don't involve sponsored research

Publication Disclosure Statements for Conflict of Interest

Journals and entities sponsoring meetings, symposia or conferences have varying standards for reporting financial relationships relating to your institutional responsibilities.  You should always acknowledge those relationships when publishing or presenting data from your research or relating to the topic of your publication or presentation.  The following are examples of disclosure statements.  If you use one of the examples, you should modify it to fit your specific relationship. The following are examples of public disclosure statements for use in publications, meetings, conferences or posters for reporting financial relationships

Example 1

The studies reported in this [publication, presentation or poster] were supported by a grant from [NIH, NSF, etc].  The [principal investigator, author, speaker] [holds stock in, serves on an advisory board or board of directors for] [Entity].   The terms of this arrangement have been reviewed and approved by University of South ³ÉÈË¿ì²¥ in accordance with its Conflict of Interest policy.

Example 2

The author(s) of this [publication, presentation or poster] has research support from [Source of research funding] and also [holds stock in; serves on an advisory board for; serves on the Board of Directors of, received an honorarium from] [name of entity]. 

Example 3

The author(s) of this [publication, presentation or poster] consults for [Entity(ies)] on [subject of consultation].   The author(s) also conducts research in areas of interest similar to the business interests of [Entity(ies)]. 

Example 4

The University of South ³ÉÈË¿ì²¥ has equity ownership in [Entity], the sponsor who funded the research reported in this [publication, presentation, poster].  The University of South ³ÉÈË¿ì²¥ may financially benefit from this interest, if [Entity] is successful in marketing products related to this research.  The terms of this arrangement have been reviewed and approved in accordance with the University’s policy on Conflict of Interest in Research.

Example 5

The research being reported in this [publication, presentation or poster] was supported by [name of sponsor funding the research].  The author(s) of this [publication, presentation or poster] [has equity ownership in, serves as an advisor for, serves on the board of director of] [Entity(ies)] which is developing products related to the research being reported. 

Example 6

The author of this [publication, presentation or poster] receives research funding from [Entity] which is developing products related to research described in this [publication, presentation or poster].  In addition, the author serves as a consultant to [Entity] and receives compensation for these services.