What is OCI?

  • Organizational Conflict of Interest (OCI) refers to an institution or organization’s other activities or relationships that prevent it from providing impartial assistance or advice to the government. 
  • It can also impair objectivity in contract work or create an unfair competitive advantage over other entities.
  • Unlike personal conflict of interest based on individual efforts or relationships, OCI arises from the institute’s overall work and interactions.
  • The Federal Acquisition Regulations (FAR) Subpart 9.5 outlines three basic categories of OCI:
     
    1. Biased ground rules (FAR 9.505-2): For example, preparing specifications or work statements used in funding opportunities.
    2. Impaired objectivity (FAR 9.505-3): This includes evaluating or assessing the products or services of others within the same organization.
    3. Unequal access to information (FAR 9.505-4): For example, gaining non-public information through the performance of a federal contract.
       

When does a proposal need to be reviewed for OCI?

  • In practice, OCI can impact proposals and contracts. Federal contracts subject to FAR often require a contracting officer to make an OCI certification or representation. 
  • To determine if your proposal or contract needs an OCI review, search the solicitation and program guidance for specific “conflict” keyword requirements.
  • If unsure, note it in the eRouting system, check the appropriate radial dial under the OCI tab, and attach or link to the Request for Proposal (RFP) for further review.
  • Remember that DoD and NASA contracts commonly involve OCI representations. Because of this, GTRI proposals entered into the eRouting system are routed for review for the actual or potential appearance of OCI.
     

What should I expect in an OCI Review?

  • During an OCI review, a committee assesses the solicitation, scope of work, and contracting database. If no concerns arise, the proposal/contract routing continues. 
  • Otherwise, the committee may interview the submitting Principal Investigator (PI) before making a final determination.
  • The timeline for an OCI review varies based on complexity but typically starts within five business days of receiving the request.
  • If there are no OCI certification requirements, the process proceeds accordingly.
     

How long does an OCI review take?

  • Complexity Dependence: The timeline for an OCI review varies based on its complexity.
  • Initiation: All reviews begin within five business days of the committee receiving the request, often sooner.
  • No Certification Requirements or Concerns: The review may conclude in a few minutes if the initial evaluation finds no OCI certification requirements or concerns.
  • Extremely Complex Cases: The process may take weeks or longer for highly complex situations, such as creating mitigation plans.
  • Simple OCI Reviews: Typically, straightforward OCI reviews conclude within one to two business days.
     

Who serves on the OCI review committee?

  • The Organizational Conflict of Interest (OCI) committee comprises members appointed by the Executive Vice President for Research (EVPR). 
  • The EVPR directly appoints one to three committee members and delegates the appointment of GTRI (Georgia Tech Research Institute) representatives to the GTRI director. 
  • The current EVPR-appointed members are Linda Mazzeo, Susan Roche, and Gail Spatt. You may contact one of them or email AVP-ROI@gatech.edu.