IORA/I-WORC NCORP is required to monitor its primary and subrecipient/affiliate sites compliance with financial Conflict of Interest (COI) regulations. This follows DHHS regulatory requirements for FCOI as outlined by NIH grants policy. This policy should ensure that there is no reasonable expectation that any investigator or staff member of the I-WORC NCORP involved in the design, conduct, or reporting of research will be biased by any conflict of interest. A management plan is also required for situations in which Conflicts of Interest are identified.