Unmanaged, significant financial interests that might present a real or perceived conflict of interest with an individual's university responsibilities can compromise the objectivity and integrity of research. To promote research integrity as well as meet federal requirements, UW–Madison requires the disclosure, review, and, as needed, management of outside activities to help ensure that research and research outcomes are free from bias.
A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's institutional responsibilities:
Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities; provided, however, that this disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
Significant Financial Interest does not include the following:
This policy applies to investigators engaging in or proposing to engage in federally funded research or any research involving human subjects. It also applies to individuals who do not hold a UW–Madison appointment, when, in accord with Federal regulations, UW–Madison carries out federally funded research through subcontractors, subrecipients, or collaborators where the terms of the agreement dictate that UW-Madison is the responsible party.
This policy operates in conjunction with other UW–Madison policies on conflict of interest that apply to all faculty members (e.g., UW-808 Faculty Policies and Procedures Chapter 8 - Faculty Rights and Responsibilities), members of the academic staff (e.g., UW-712 Academic Staff Policies and Procedures: Chapter 12 - Outside Activities and Conflicts of Interest), university officials (e.g., UW-4002 Institutional Conflicts of Interest), and university staff (see Regent Policy Document 20-22, Code of Ethics), as well as UW-1075 Conflict of Commitment.
UW–Madison has adopted this policy and its attendant guidelines to incorporate the requirements set forth by the US Department of Health and Human Services (42 C.F.R. § 50, Subpart F and 45 C.F.R. § 94) the National Science Foundation (NSF 510), and other federal funding agencies to promote integrity and objectivity in research.
Research involving human subjects, regardless of funding source, requires disclosure, review, and, when appropriate, management of Significant Financial Interests (SFI). In these circumstances, this policy works in conjunction with UW-4145 Institutional Review Board (IRB) Review and HRP-055, SOP: Financial Conflicts of Interest, with a primary focus on promoting research integrity and ensuring that research is free from bias due to financial conflicts of interest.
Additional information about this policy's supporting processes and procedures is in the Financial Conflict of Interest Policy and Procedures: Guidance Document.
11-24-2020, 01-22-2021, 08-28-2023, 10-25-2023, 05-07-2025
05-07-2025