Organizational Conflict of Interest (“OCI”) – What is it?

2016-06-07

Organizational Conflict of Interest (“OCI”) – What is it?

“Organizational Conflict of Interest” means that because of other activities or relationships with other entities, the institution is unable to render impartial assistance or advice to the Government, cannot perform the federal contract work in an objective way, or has an unfair competitive advantage compared to other entities.

Organizational Conflict of Interest (OCI) could result when the nature of the work being performed on a federal contract creates an actual or potential conflict of interest on a future award, which could result in restrictions on that award.   There are three basic categories where OCIs may be found:

  • biased ground rules (FAR 9.505-2): Example – preparing/writing specifications or work statements that are used in a funding opportunity;
  • impaired objectivity (FAR 9.505-3): Example – evaluating or assessing performance of products/services of others within same organization; and
  • unequal access to information (FAR 9.505-4): Example – gaining access to non-public information (i.e., budget(s)/budget information, statements of work, evaluation criteria, etc.) through performance of a federal contract.

One faculty member’s involvement in one of these situations may preclude a subsequently related award (and different faculty member) from being received at the University on the basis of a potential OCI.

FAR 2.101 includes the Definition of OCI.

FAR Subpart 9.5 further describes the general rules, responsibilities, and procedures regarding Organizational and Consultant Conflicts of Interest.

8/9/17 Update: Please see University Policy 11-01-08 on Organizational Conflict of Interest