How are Conflicts of Interest Reviewed and Managed?

Annual COI disclosures are reviewed to determine whether a conflict of interest exists and, if so, to implement appropriate management strategies. 

A preliminary review of the disclosure is conducted to determine whether a potential conflict of interest exists, given the employee's interests and activities with external entities, and their existing relationships with other NDSU employees or students.  The COI Administrator may consult with the employee to obtain additional information or to clarify information in the Annual Disclosure.

If there are no relationships or activities reported that present a potential conflict, the review is completed at this stage.

If the COI Administrator determines that there is a potential COI, the disclosure will be referred for secondary review.

The secondary reviewer may determine that a standard management plan is sufficient to manage potential conflicts.  If so, a management plan is drafted with the employee and reviewed via expedited procedures by the secondary reviewer and the COI committee chair.

More complicated conflicts may require review by at a convened meeting.  This will include drafting a management plan that specifically addresses any unusual circumstances. To assist in these reviews, the Conflict of Interest may involve representatives from the employee's department, Research and Creative Activity, and/or seek legal guidance as necessary.