Managing a Potential Conflict of Interest
or Conflict of Commitment

What are some of the ways in which COI/COC managers could address potential COI/COCs? 

A COI/COC manager may select one or more of a range of actions, some of which are described below.

• Document that the faculty member has disclosed the potential COI/COC, with no further action required. 
• Take steps to ensure that the outside activity/employment does not conflict with the faculty member’s ability to carry out his or her obligations to the University.
• Disclose the situation to appropriate persons within the UM or to appropriate persons or organizations outside the UM.
• Modify the faculty’s member’s duties with regard to managing, supervising, evaluating, or mentoring other persons where those activities contribute to the potential COI/COC. 
• Reduce the faculty member’s appointment to permit time to be spent on the non-University activity.
• Request competitive bids for a service/product provided by an entity where the faculty member has a financial interest.
• Obtain Regents’ approval to proceed with a contract where the faculty member has a special interest (including financial) in the outside supplier/vendor/consultant.
• Make sure the faculty member isn’t involved in decision-making related to the outside activity/employment.  Examples:  no involvement in drafting a Request for Qualifications (RFQ), no involvement in selecting consultants, no oversight of outside entity when that entity is doing work for UM, etc.
• Refuse to permit the faculty member to participate in the outside activity/employment.