Additional course links
You leave with: A conflict register built around application and reviewer, and a tested reassignment record for Horizon's A-17.
Where this fits: In Lesson 2, reviewer R3 declares a board seat at the organization behind A-17, and A-17 is reassigned before scoring. That takes one sentence in the lesson. This deep dive shows what has to be true for that sentence to hold up when an auditor or a disappointed applicant asks: the register, the decision, the reassignment and the access test. You bring back a conflict register and a reassignment record for step 2 of the workbook.
Track reviewer conflicts of interest by recording each declaration against a specific application, having the owner named in your policy decide what it requires, and linking that decision to assignments and access. Keep who decided, when it took effect and what happened to any work already done. A register is only useful if assignment, discussion and the final decision follow it, so test the controls rather than trusting a status label.
Keep declarations, decisions and actions separate
A reviewer's declaration identifies a relationship or interest. The owner named in the program's policy decides what the policy requires. The system then has to reflect that decision in assignments, access and the record of review. Those are three different records, made by different people at different times.
An empty declaration field does not mean "no conflict". It may mean the reviewer has not done the check yet. A possible match found in the records is not a conflict finding either. Keep those states distinct.
| Stage | Record | Check before going on |
|---|---|---|
| Declaration | Reviewer, application, relationship, date, policy version | Has every reviewer completed it for this round? |
| Assessment | Owner, conclusion and reason | What does the policy require here? |
| Action | Recusal, reassignment or access change | Has the action actually taken effect? |
| Decision record | Who took part, affected assessments, final approval | Could someone else reconstruct what happened? |
A published example: NIH links conflicts to participation
NIH's peer-review conflict guidance gives the example of a reviewer employed by an applicant institution who cannot review that application or take part in its discussion, while potentially reviewing other applications. NIH also publishes pre- and post-review conflict certification documents.
Those are NIH requirements, not a policy for every foundation or fellowship. The transferable lesson is that a declaration is tied to participation in a specific application, and the record is checked again after review, rather than a signed annual form standing in for the whole process.
Build the register around the application and reviewer
Use stable IDs for the reviewer, the application and the round. A note on an organization's profile saying "board connection" is too broad to act on. The owner needs to see which application is affected and which participation is still permitted. Here is Horizon's entry for A-17.
| Field | A-17 · Horizon example, fictional |
|---|---|
| Declaration | R3, round R-2, application A-17: serves on the applicant organization's board. Declared before assignment. |
| Policy | Horizon's reviewer conflict policy, current version |
| Decision | Conflict requiring recusal from A-17; reason, owner and effective date recorded |
| Assignment | A-17 moved from R3 to R5; R5's own declaration for A-17 checked first |
| Access | R3 cannot open A-17 or its files; tested with a test account before scoring began |
| Review history | No score, comment or discussion from R3 on A-17 |
Keep sensitive details visible only to the people who need them. A reviewer's dashboard may need to show "not assigned" without exposing the relationship; an authorized audit view keeps the reason.
Check before assignment and when circumstances change
Give reviewers enough information to declare against the actual list of applications, such as organization names and key partners, before anything is assigned. A generic annual statement does not cover a new round's applicants. Horizon's six reviewers declare against the 64 R-2 applications before the reading is distributed, which is how R3's board seat surfaced in time.
Where the policy requires recusal, remove the application from the reviewer's work and reassign it through the approved process. Confirm the replacement has completed their own check; reassigning A-17 to a reviewer with a different undeclared connection solves nothing.
Circumstances change during a round. A reviewer may join a board, take a new job or recognize a name in a partner letter halfway through. Give reviewers a way to update a declaration at any point, and record a new disclosure even when review has started. The owner then decides what happens to earlier work.
Worked example: the same conflict, found after scoring
At Horizon, R3's conflict surfaced before scoring, so nothing had to be undone. Change one fact for practice: suppose R3 had recognized the connection only after entering a draft score for A-17. The record has more to carry.
Horizon example · fictional variation
Record the declaration. Link it to R3, A-17 and R-2, with the date it was made, which is after the draft score.
Record the owner's decision. Recusal required; reason and effective time.
Stop further participation. Remove R3's access to A-17 and exclude R3 from its committee discussion.
Mark the earlier work. The owner decides R3's draft score must not contribute. It stays in the history, marked excluded with the reason. It is not deleted and not averaged with the replacement score.
Reassign. R5 completes a declaration for A-17, then reviews it from the application and its Intelligence Cell reading, not from R3's notes.
Verify. Before the committee meets, confirm A-17's final assessment contains only R5's work and that R3's participation record shows the exclusion.
Deleting the old score would make the record look clean and leave it unexplainable. Averaging it would let the conflict shape the result. Keeping it visible and excluded is the version an auditor can follow.
Test access, not the label on the record
A status of "recused" is a label; access is what you test. Log in with a test account set up like the recused reviewer and try every route: the application list, a direct link to the record, the attached files, any exports and shared views.
In an AI-native cycle there is one more route to test. If reviewers can ask the AI Assistant questions across the round, check what it returns to the recused reviewer about A-17. The Assistant should follow the same permissions as the record itself.
Some routes sit outside the system. Removing an assignment does not revoke a file someone already downloaded or a document forwarded by email. Follow your organization's handling process for those, and do not claim a control you have not tested.
In Sopact Sense, set the permission, assignment and history controls for your program before the round opens, then run the same tests. AI can surface a possible relationship in the records it can see, such as a reviewer's name in a partner letter; the declaration and the policy decision stay with people.
Preserve the reason for a score change or override
Keep the original assessment, the revised one and the explanation distinguishable. A useful record shows the source evidence, the rubric version, who made the change and who approved it where the policy requires. The same applies when a reviewer overrides an AI reading: the override and its reason are part of the decision record.
Before you call an activity log an audit trail, ask what events are captured, what can be edited, who can see the log and how it is retrieved under your retention rules.
For each important change, ask one practical question: could a colleague who was not in the meeting understand why the final record differs from the first assessment?
Review the round before closing it
Before R-2's awards are approved, check for missing declarations, assignments still waiting for clearance and any decision made before a required action took effect. Confirm the committee's materials include only assessments the process permits.
Keep the participation record with the decision materials, under the right access and retention rules. A record that lives only in one administrator's inbox will be hard to reconstruct after that person moves on, which is the same risk as the workflow nobody dares touch.
Use what went wrong to improve the next round: unclear declaration wording, a late reassignment, an export that bypassed the access rules. Fix the process rather than relying on everyone remembering the exception.
Put it into practice
Reconstruct one reassignment
- Build a register entry for A-17 and R3 with the six fields above, using test records, not real declarations.
- Have a colleague act as the policy owner and record the decision, reason and effective date.
- Reassign A-17 to R5, record R5's declaration first, and list every access route you would test for R3, including the AI Assistant.
- Now apply the variation: R3 declares after entering a draft score. Record how the draft is marked and why it is not deleted or averaged.
- Ask another colleague to explain the final A-17 assessment from the record alone. Carry the register into step 2 of the workbook.
Download the workbook (PDF)
Practice data: horizon-r2-applications.csv · horizon-rubric.csv · calibration-scores.csv · eastgate-q1-update.csv
Check your reasoning before moving on
Your record should show four things in order: R3's declaration against A-17, the owner's decision with a reason, the reassignment to R5 after R5's own check, and an access test that covered the list, direct link, files, exports and the assistant. In the variation, R3's draft score stays in the history marked excluded, and A-17's final assessment contains only R5's work. If your colleague cannot explain the outcome without asking you, a step is missing. The conflict never lowers A-17's score; it changes who reviews it.
Questions grant teams ask
What should a reviewer conflict register contain?
One entry per reviewer and application: the declaration and its date, the policy version applied, the owner's decision and reason, the action taken such as recusal or reassignment, the evidence that access changed, and how any earlier review work was handled. Use stable IDs for reviewer, application and round so the entry can be matched to the scores and the final decision.
Is a declaration the same as a conflict decision?
No. A declaration supplies information about a relationship or interest. The owner named in the policy decides what it means and what action is required, and records the reason. Keeping the two separate shows who made the call and on what basis, which matters when a decision is questioned later.
What if a conflict is discovered after a score is entered?
Record the new declaration with its date, have the policy owner decide how the earlier work is handled, and apply the access and discussion restrictions straight away. Keep the earlier score in the history, marked excluded with the reason, rather than deleting it or averaging it with a replacement. Reassign after the new reviewer's own check, and verify the final record before the committee decides.
Does removing an assignment revoke all access?
Not necessarily. Test the application list, direct record links, attached files, exports, shared views and any AI assistant that answers questions across the round. Files already downloaded or forwarded sit outside the system and need separate handling under your organization's process. Record what you tested and when.
Can AI detect every conflict?
No. AI can surface possible relationships in the records it can read, such as a reviewer's name appearing in a partner letter or board list. It cannot know about relationships that appear nowhere in the data, and it does not make the policy decision. Use it to prompt a declaration or a question, not to replace either.
Is a change log automatically an audit-ready record?
No. Check what events it captures, who can edit it, who can see it and whether the decision can be reconstructed from it. The test is practical: someone outside the meeting should be able to follow what changed, who changed it and why.