Track reviewer conflicts of interest by recording declarations against specific applications, having an authorized person assess them under the program’s policy, and linking that decision to reviewer assignments and access. Preserve who made the decision, when it took effect and what happened to any work already completed. A conflict register is useful only if the assignment, discussion and decision process follow it.

By Sopact Academy · Reviewed September 12, 2026. This lesson combines cited public guidance with practical workflow recommendations. Figures and teaching scenarios are illustrative unless explicitly identified as a published case.

Keep declarations, decisions and actions separate

A reviewer’s declaration identifies a relationship or interest. The program’s designated owner determines what action the policy requires. The system then needs to reflect that action in assignments, access and the record of review.

Do not treat an empty declaration field as “no conflict.” It may mean the reviewer has not completed the check. Equally, a potential match is not a final conflict finding. Keep those states distinct.

A published example: NIH links conflicts to participation

NIH’s peer-review guidance gives an example of a reviewer employed by an applicant institution who cannot review that application or participate in its discussion, while potentially reviewing other applications. NIH also publishes pre- and post-review conflict certification documents.

Those are NIH-specific requirements, not a universal policy for foundations, awards or fellowships. The operational lesson is to connect a declaration to participation and verify the record after review, rather than treating a signed form as the entire process.

Build the register around the application and reviewer

Use stable identifiers for the reviewer, application and round. An organization-level note alone can be too broad or too vague. The owner needs to see which application is affected and which participation is permitted.

• Declaration: who declared, what relationship was disclosed and when.
• Policy: the rule or policy version considered by the authorized owner.
• Decision: conclusion, reason, owner and effective date.
• Assignment: original reviewer, replacement if needed and assignment status.
• Access: the intended restriction and evidence that it was checked.
• Review history: any affected score, comment, discussion or recommendation and its handling.

Keep sensitive details available only to the appropriate people. A general reviewer dashboard may need to show “not assigned” without exposing the full relationship declaration. An authorized audit view can retain the underlying reason.

Check conflicts before assignment and when circumstances change

Give reviewers enough permitted information to make the required declaration. Do not assume a generic annual statement covers every application in a new round. Follow the program’s process for updating declarations if a reviewer recognizes a relationship later.

Where the policy requires recusal, make the application unavailable for the affected review activity and reassign it through the approved process. Confirm the replacement reviewer has completed their own check. Reassignment does not automatically solve a conflict if the replacement has not been assessed.

Record a newly disclosed issue even when review has started. The authorized owner must decide what happens to earlier work and whether additional review is needed. Do not erase the record of the issue merely because it is inconvenient.

Worked example: a conflict found after scoring

In this fictional exercise, reviewer R-07 has already drafted an assessment of application A-104. The reviewer then declares a relationship that the program owner determines requires recusal under the program’s policy.

1. Record the declaration: link it to R-07, A-104 and the round.
2. Record the owner’s decision: include the reason and effective time.
3. Stop further participation: apply the required access and discussion restrictions.
4. Preserve earlier work: mark how the owner has decided the draft assessment should be handled; do not leave it silently in the total.
5. Reassign: choose an eligible replacement and complete their conflict check.
6. Verify: inspect the final assessment and participation record before the decision is approved.

For this exercise, assume the owner decides the earlier draft must not contribute to the final assessment. Keep that exclusion visible. Do not simply average the old and new scores, and do not present deletion of the old score as a complete history.

Test access, not just the label on the record

A status of “recused” does not prove that a person can no longer open the application. Test the actual workflow with an authorized test account: the application list, direct record link, attached files and any reviewer exports or shared views.

Different channels may have different controls. Removing an assignment may not revoke an already downloaded file or a separately shared document. Follow the organization’s handling process for those materials and avoid claiming a control that has not been tested.

In a Sopact implementation, confirm which permissions, assignment controls and history records are available and configured for the use case. AI can help surface a possible relationship in supplied records, but it cannot establish that every conflict has been declared or make the policy decision on its own.

Preserve the reason for a score change or override

Keep the original assessment, revised assessment and explanation distinguishable. A useful record shows the source evidence, rubric version, person making the change and approving owner where required.

Do not describe an editable activity log as an immutable audit trail unless that property has been established. Ask what events are captured, what can be edited, how access is controlled and how the record can be retrieved under the organization’s retention process.

For each important change, answer a 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

Check for unresolved declarations, assignments awaiting clearance and decisions made before required actions took effect. Confirm that the final summary includes only assessments permitted by the process.

Keep the participation record with the decision materials, subject to the applicable access and retention rules. A record that lives only in one administrator’s inbox will be difficult to reconstruct when staff change.

Use recurring issues to improve the next round: unclear declaration wording, late assignment changes or exports that bypass the intended review access. Improvement should address the process, not rely on everyone remembering an exception.

Exercise: reconstruct one reassignment

Create a fictional declaration for R-07 and A-104. Have a colleague act as the program owner and record the required decision under a sample policy supplied for the exercise. Use test records, not real confidential declarations.

Trace the assignment change, earlier draft assessment and replacement review. Then ask another colleague to explain the final decision from the record alone.

Pass condition: the record shows the declaration, policy decision, action taken and treatment of earlier work. Access controls have been tested rather than assumed from a status label.

Frequently asked questions

What should a reviewer conflict register contain?

Record the reviewer, affected application and round, declaration, policy assessment, authorized decision, action taken and treatment of any earlier review work.

Is a declaration the same as a conflict decision?

No. A declaration supplies information. The designated owner applies the relevant policy and records the required action.

Can a system automatically recuse a reviewer?

A configured system may enforce approved assignment or access rules, but the policy and decision authority must be established. Test the actual controls rather than assuming that a status label changes access.

What if a conflict is discovered after a score is entered?

Record the issue and have the authorized owner determine how earlier work should be handled. Preserve the history, apply required restrictions and complete any reassignment or additional review.

Does removing an assignment revoke all access?

Not necessarily. Check record links, files, shared views and exports. Previously downloaded material may require separate handling under the organization’s process.

Can AI detect every conflict?

No. AI can help identify possible relationships in available records, but it does not replace reviewer declarations or the authorized policy assessment.

Is a change log automatically an audit-ready record?

No. Verify what events are captured, who can edit them, how access is controlled and whether the decision can be reconstructed. Do not claim immutability or compliance without evidence.

Return the tested conflict process to your module

The related lesson moves to reading a grantee report across different types of evidence. Keep the habits established here: distinguish a signal from a decision, identify the responsible reviewer and preserve the source and reason behind a change.

Related batch-review practice: analyze an application batch →

course overview