This policy is provided to help the University examine circumstances surrounding gifts, grants and personal holdings, and manage (through disclosure, separation of responsibilities or other appropriate requirements), any actual or apparent conflicts of interest that may result.
Institutional Conflict of Interest.
The institution may have a conflict of interest (“Institutional COI” and also ICOI) whenever the financial interests of the institution, or of a University Official acting within his or her authority on behalf of the institution, might affect – or reasonably appear to affect – institutional processes for the selection, design, conduct, reporting, review, or oversight of the University enterprise. For the purposes of evaluating ICOI, activities related to research, teaching and outreach, and the administration of those functions, singly and collectively represent the University enterprise.
University Official shall mean persons with the power to commit substantial resources of the University. University Officials include, but are not limited to, Chancellors, Vice Chancellors, Provosts, Vice Provosts and Deans, including those holding these positions in an interim capacity. These individuals have a responsibility to identify others who have discretionary authority to allocate resources related to the University enterprise.
Significant Financial Interest. For the purposes of evaluating ICOI, the definition of a Significant Financial Interest will be the same as stated in the Code of Federal Regulations at 42CFR50.603 (see Appendix I).
Appendix I: Definition of Significant Financial Interest
Significant financial interest means an interest consisting of one or more of the following interests of a University Official (and those of the University Official’s spouse and dependent children) that reasonably appears to be related to the University Official’s institutional responsibilities:
The University operates through the actions of University Officials, individuals with administrative authority and responsibility. This policy governs institutional conflicts of interest at the University and applies to University Officials.
The Wisconsin Alumni Research Foundation (WARF), the University of Wisconsin Medical Foundation (UWMF), the University of Wisconsin Hospital and Clinics (UWHC), the Morgridge Research Institute, WiCell, and the University of Wisconsin Foundation (UWF) are organizations that are separate and independent from the University. Because of the independent nature of these organizations, unless specifically addressed in this policy, the actions of these organizations are sufficiently outside the control of the University or a University Official that no Institutional COI evaluation is needed.
This policy does not govern situations in which individuals who are not University Officials might realize financial gain from the conduct of research or performance of other responsibilities at the University; the University’s Conflict of Interest Committee, using existing policies and procedures, adequately identifies such situations and independently manages their associated risks to scientific objectivity and proper treatment of human subjects.
As the University of Wisconsin–Madison (University) collaborates with an ever-expanding network of affiliated organizations to apply the fruits of research and scholarship to benefit society, the potential exists for institutional conflicts of interest. The following policy signals our commitment to the disclosure, identification, and management of institutional conflicts of interest.
The following principles shall guide the University in addressing Institutional COI:
Institutional financial or business considerations must not be allowed to undermine the objectivity of research, teaching and outreach at the University.
The numerous and complex relationships between the University and public and private entities require the University to be aware of any relationships that may compromise or appear to compromise its integrity.
The University’s Conflict of Interest Committee, using existing policies and procedures, identifies situations in which individuals might realize financial gain from the conduct of research at the University and independently manages the risks to scientific objectivity and proper treatment of human subjects associated with such situations.
The Board of Regents of the University of Wisconsin System, the UWF, and the University have established policies regarding the acceptance of extramural support, including gifts, grants, contracts, and cooperative agreements. These policies apply to University Officials as defined here and are summarized below.
All gifts and grants to the University must be accepted in conformance with the following policies:
UW System Administrative Policy 342 (formerly G2), Extramural Support Administration: https://www.wisconsin.edu/uw-policies/uw-system-administrative-policies/extramural-support-administration/
Policies regarding the acceptance and disposition of gifts made to the UW Foundation: http://www.bussvc.wisc.edu/acct/gifts/UW–MadisonandFoundationPolicies.pdf
University policies regarding the acceptance and disposition of gifts in kind: http://www.bussvc.wisc.edu/acct/gifts/Gift-in-KindPolicy.pdf
University policies regarding the acceptance and disposition of gift checks made directly to the university: http://www.bussvc.wisc.edu/acct/gifts/gifts.html
The following circumstances should be evaluated when considering decisions to commit substantial resources of the University or when University Officials are responsible for the direction/control of significant University activities:
The Significant Financial Interests of University Officials involved in decisions regarding the activity, and
Nexus between Significant Financial Interests and the activity.
The Chancellor, or his/her designee, has the authority to implement disclosure and review processes, to oversee procedures to address Institutional COI, and to develop and monitor plans for managing, reducing or eliminating Institutional COI, involving:
In these instances of conflict of interest, the Office of the Vice Chancellor for Research and Graduate Education’s Associate Vice Chancellor for Research Policy and Integrity shall consult with the Chancellor.
In instances where the Chancellor may have an Institutional COI, he or she must recuse himself or herself and defer to the President of the University of Wisconsin System, who will review, create and approve management plans in consultation with the Office of the Vice Chancellor for Research and Graduate Education’s Associate Vice Chancellor for Research Policy and Integrity shall consult with the Chancellor.
University Officials and other individuals covered under this policy shall, upon appointment and annually thereafter, file a financial disclosure statement with the Office of the Chancellor disclosing Significant Financial Interests. For those required to file it, a Wisconsin Statement of Economic Interests is sufficient to fulfill this disclosure requirement. Those not required to file a Wisconsin Statement of Economic Interests will receive a university form designed for this process.
University Officials and other individuals covered under this policy shall disclose to campus Institutional Review Boards (IRBs) any conflicts of interest they may have, as well as any management plans or exceptions to management issued by the COI Committee, with regard to their human subjects research activities reviewed by the campus IRBs. Such disclosures occur by answering the standard conflict of interest questions in IRB applications. (See "Financial Conflicts of Interest in Human Subjects Research: Policies and Procedures, Appendix 2. Procedures, (a) Reporting, (ii) To IRBs", found at https://research.wisc.edu/respolcomp/hrpp/).
University Officials and other individuals covered under this policy shall provide a revised financial disclosure statement through appropriate Outside Activities Reporting processes within 30 days of acquiring any new Significant Financial Interests.
Related document: Institutional Conflict of Interest (ICOI) Procedures (https://kb.wisc.edu/gsadminkb/page.php?id=58576)
Significant financial interests do not include the following: