COI in L&S: Conflict of Interest Committee
This document gives an overview of the UW-Madison Conflict of Interest Committee and their review of Outside Activities Reports (OARs) for any significant financial interests (SFIs) or financial conflicts of interests (FCOIs).
OARs in L&S are reviewed at the departmental or center level, usually by department chairs. They are also reviewed at the Division level in the College of Letters and Science by the Associate Dean for Research Services, or their designee. In addition, OARs are reviewed by the COI Program Staff within the graduate school. Typically, the COI Program Staff determines whether any activities reported on an individual's OAR represent a Significant Financial Interest (SFI). SFIs are described in this document COI: L&S OAR Review Process.
The UW-Madison Graduate School has the responsibility and authority to identify Financial Conflicts of Interest based upon SFIs. The Vice Chancellor for Research and Graduate Education delegates this responsibility and authority to the Associate Vice Chancellor for Research Policy, who manages the COI Program. The Chancellor appoints the voting membership and ex officio participants of the COI Committee based upon the recommendation of the Vice Chancellor for Research.
The purpose of the Conflict of Interest (COI) Committee is to review outside activities of faculty and staff for possible individual financial conflicts of interest (FCOI) with their research. All individuals who are key personnel on federal grants or listed on human subjects protocols are included in the COI Committee's review.
The COI Committee is made up of 12-18 voting members and a chair. Both faculty and academic staff may be members, and members represent a wide range of disciplines and colleges on campus. The committee seeks to maintain a balance of clinical and non-clinical researchers, of individuals engaging in entrepreneurial activities and not, and of representatives from larger and smaller colleges. The committee also works with faculty and staff to eliminate, minimize or manage any actual or potential conflicts of interest identified by the disclosure process.
If a SFI is identified by the COI Program, the OAR is then sent to the Conflict of Interest Committee. The COI Committee may also review SFIs at the request of the Dean's Office or a UW-Madison IRB. The COI Committee will evaluate whether the SFI could directly and significantly affect the design, conduct, or reporting of federally funded or human subjects research or whether the financial interests of the outside entity could be directly and significantly affected by the research. Majority vote of the COI Committee identifies (FCOI), assigns management plans, permits exceptions, and provides termination of management plans.While assessing the need for a management plan, the COI Committee considers whether an outside activity or financial interest has a "nexus" with individual's research activities at the UW-Madison. An outside activity has a nexus with an individual's research activity if the outside activity arises from or relies upon the academic expertise that qualifies that individual to participate in federally-funded or human subjects research and the outside activity could directly affect the research.
For more information on Management Plans, see this KnowledgeBase document COI in L&S: Management Plans .
For detailed information on SFIs, FCOIs, the COI Committee, and the importance of the review process for sub-recipients on PHS-federal awards, please see the UW-Madison Office of Research Policy Conflict of Interest Policy and Procedures: Guidance Document.