OverviewBack to TopIn order to identify potential or actual conflicts of interests, faculty and academic staff must annually disclose outside activities and financial interests related to their field(s) of work at UW-Madison via an Outside Activities Report (OAR).
A Conflict of Interest (COI) exists when an investigator has a financial or other interest that could raise questions about whether the design, conduct or reporting of research might be influenced by the possibility of personal gain.
Federal policies require the University to eliminate, minimize, or manage any potential or actual conflicts of interest between an investigator’s federally-funded research and significant financial interests that might reasonably appear to affect, or be affected by, the federally-funded work.
GuidelinesBack to Top
Filing an OAR
- Submit reports online at www.grad.wisc.edu/coi/disclose.html
- Reports are due by April 30 each year
- Reports must be filed by personnel below, even if no outside activities have taken place
State and University policies require annual reporting of outside activities from:
- Faculty members, including those with 0% appointments
- Academic staff with 50% or greater appointments
- Anyone listed on a Federal grant or Human Subjects Protocol, including students
What Must Be Reported?
- Outside compensation
- Leadership positions
- Ownership interests
For a complete list of reportable and non-reportable items, see:
- UW-Madison COI Policy and Program: Guidance Document (pdf) (pages 7, 8 and 16)
Updating an OAR
An OAR must be updated whenever there is a significant change in:
- Outside activities or financial interests
- Relationships with outside organizations
- Research activities
OARs must be upated within 30 days of acquiring a new outside financial interest. Investigators with Public Health Services (PHS) funding that miss the 30 day requirement will need to meet an additional review process.
TrainingBack to TopEffective August 24, 2012, UW-Madison COI policy requires that all investigators engaged in federally funded and/or human subjects research complete training in Financial Conflict of Interest.
Sub-recipient investigators on UW-Madison PHS awards must also complete UW-Madison COI training, if the sub-recipient has agreed to comply with UW-Madison COI policy.
- COI training is offered online through Learn@UW
- See the Graduate School COI Training page for registration instructions and additional information.
- COI training must be completed every four years
Review ProcessBack to Top
Conflict of Interest Committee
OAR submissions are reviewed annually by the UW-Madison Conflict of Interest (COI) Committee.
The COI Committee determines whether conflicts exist and assigns COI management plans in cases where significants conflicts are found.
Management Plans vary depending on the level of conflict, but plans may require investigators to:
- Disclose financial interests in publications/presentations
- Disclose of financial interests to students, staff, and co-investigators
- Disclose proposed resarch support from outside entities to the Dean’s Office
- Obtain facilities use agreements before use occurs
- Have oversight of purchases from outside entities
- Complete an annual review of the management plan
Review ProcessBack to TopThe COI Program Staff and/or COI Committee will review an investigator’s Outside Activities Report (OAR) to determine whether any of these activities represent a Significant Financial Interest (SFI).
Review of SFIs
A Significant Financial Interest may be a financial conflict of interest if the interest could directly and significantly affect the design, conduct, or reporting of research.
Conflict of Interest Committee
- Reviews all investigator disclosures of significant financial interests on their outside activity report.
- Determines whether any significant financial interests relate to the investigator’s research
- Determines whether a financial conflict of interest exits
- If so, develops and implements a management plan that specifies actions that have been, and shall be, taken to manage the financial conflict of interest.
Conditions of Management Plans
“Manage” means taking action to address a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.
Examples of conditions or restrictions that might be imposed to manage a financial conflict of interest:
- Disclose to co-investigators, staff, postdoctoral researchers and students of the existence of the financial conflict of interest
- Public disclosure of financial conflict of interest when presenting or publishing research
- Research projects involving human subjects, disclosure directly to study participants of financial conflicts of interest
- Appointment of an independent monitor capable of taking measures to protect the design, conduct, and reporting of the research
- Modification of the research plan
- Change of personnel or personnel responsibilities, or disqualification of personnel from participation in all or a portion of the research
- Reduction or elimination of the financial interest
ContactsBack to Top
General Compliance Questions
CALS Research Compliance Specialist
Campus COI Contact