Organizational Conflicts of Interest (OCOI)

Organizational Conflicts of Interest can arise at both the individual or business level. Organizational conflict of interest means that because of other activities or relationships with other persons, a person is unable or potentially unable to render impartial assistance or advice to the Government, or the person’s objectivity in performing the contract work is or might be otherwise impaired, or a person has an unfair competitive advantage.

The University is responsible for identifying potential Organizational Conflicts of Interest (OCI) described in Subpart 9.5 of the Federal Acquisition Regulation that may provide an employee and/or another member of the University with an unfair competitive advantage in applying for federal funding or that could appear to bias its judgment.  Failure to address OCIs may adversely affect the University’s ability to compete for certain federal funding.

An OCI may occur, for example, if a member of the University community provides advice, scientific, engineering or technical direction to the federal government, prepares the specifications or statement of work for a federal funding opportunity, or evaluates the work performed by another member of the University under a federal contract.

Concerns Related to OCIs

OCIs involve one of three situations:

• Unequal access to information: ECU may have an unfair competitive advantage resulting from access to information not generally available to others seeking the same federal funding.
• Impaired objectivity: At the government’s direction, ECU may be asked to assess performance or evaluate products of someone within ECU or ECU’s direct competitor seeking federal funding.
• Biased ground rules: An ECU faculty or staff member may have provided scientific, engineering or technical assistance or written the work requirements for a funding opportunity where someone else at ECU is an applicant.

Disclosure

Sometimes OCIs are unavoidable, but disclosure is required in an effort to be transparent and take necessary steps to manage them.

All members of the University community must disclose activities they perform as employees of the University and/or in their personal capacity as independent consultants or otherwise that may give rise to OCIs.  The project-specific disclosure process provides an opportunity for personnel to disclose this information.