It is the policy of UW–Madison to ensure that research is not biased in its design, conduct, or reporting, and to ensure especially the protection of human subjects, by requiring disclosure and review of certain outside activities, and where appropriate, by managing and reporting significant financial interests that might present a real or perceived conflict of interest with an individual's institutional responsibilities in such a manner as to appear to directly and significantly compromise the integrity of research.
The following definitions apply solely to the use of the terms in this policy and its attendant guidelines.
This policy applies to investigators engaging in - or proposing to engage in - federally funded research or any research involving human subjects. Generally, the UW–Madison Conflict of Interest Committee does not review or manage outside activities of individuals who do not hold a UW–Madison appointment. However, in accord with Federal regulations, when UW–Madison carries out federally funded research through subcontractors, subrecipients, or collaborators, the terms of the agreement between the parties will dictate whether this policy or the policy of the other party applies to the subrecipient investigator(s).
According to the National Institutes of Health, a potential financial conflict of interest exists when an investigator has significant financial interests that could lead an independent observer to reasonably question whether the design, conduct, or reporting of research might be influenced by the possibility of personal gain to the individual or to his or her immediate family. Others define conflict of interest situations in terms of obligations. Two activities may interact such that judgment in one activity may be, or may seem to be, influenced by the other activity. Together, these two definitions identify important elements of conflicts of interest. Conflicts of interest:
Significant financial gains are considered to be of ultimate relevance in the current context for understanding conflicts of interest because money is recognized by the general public to be a potent motivator -- one that is easily understood, easily quantified, and discretionary. While the focus of conflict of interest considerations is financial gain, other relevant interests inherent in academia, including prestige, promotion, grants, and publications, can also potentially exert influence over research activities.
Because financial conflicts of interest could contribute to bias in research reporting, influence judgment, reduce free exchange of research findings, pose a threat to research integrity, and compromise the protection of human subjects, UW–Madison has legal and ethical responsibilities to review and manage potential financial conflicts of interest in research.
Furthermore, The University of Wisconsin–Madison receives funding from the U.S. Government that requires the University to comply with Federal Acquisition Regulations (FAR), Defense Federal Acquisition Regulations, and other contractual requirements. The purpose of these requirements is to assure impartial assistance, promote objectivity in research, prevent unfair competitive advantage, and protect proprietary or sensitive information received by the recipients of federal funding.
Employees of the university may act in a capacity that provides them with access to proprietary data of the Government or may provide the Government with scientific or technical direction; analysis, assistance, advisory, or evaluation services; preparatory specifications or work statements while carrying out their university responsibilities.
An organizational conflict of interest (OCI) may exist when access to the types of privileged information described above may prevent University of Wisconsin–Madison from providing impartial assistance or advice to research sponsors, impair its objectivity in performing research, or give an unfair competitive advantage in competition for Government funding.
The attestation plan will be presented to all participants in the contract or agreement by representatives of the OVCR Office of Research Policy and leadership of the department, institute or center for review and signature before work can proceed. Copies of the signed attestation will be provided to the requesting sponsor, OVCR Office of Research Policy, the department, institute or center, and the participant.
The leadership of the department, institute or center will provide a bi-annual report on status of compliance with the attestation plan to the OVCR Office of Research Policy.
Ongoing after the enactment of an OCI attestation plan, the leadership of the department, institute or center will provide assessments of newly proposed contracts and their relevance to existing attestation plans. If potential OCI concerns are identified, the leadership will enact additional measures to prevent University of Wisconsin–Madison from providing impartial assistance or advice to research sponsors, impair its objectivity in performing research, or give an unfair competitive advantage in competition for Government funding.
11-24-2020, 01-22-2021, 08-28-2023, 10-25-2023