1. UW Conflict of Interest Program Manager Office of Research Policy
CONFLICTS OF INTEREST
University Hat
Kelly Ullrick, J.D.
UW Conflict of Interest Program Manager
Office of Research Policy
UW Graduate School

2. What is a Financial Conflict of Interest?
A conflict of interest exists when an investigator has a significant financial interest 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 (individual or immediate family)

3. UW Perspective The University encourages faculty and staff to:
Engage in outside activities
Share expertise
Transfer intellectual property to the private sector
The University asserts that:
Conflicts of interest are common and frequently unavoidable
Conflicts of interest are not inherently “bad”
Conflicts of interest can often be managed by using a series of best practices, i.e., management plans

4. Significant Financial Interests
OUTSIDE ACTIVITIES OF MONETARY VALUE, including but not limited to:
Compensation for outside activities exceeding $10,000 in any single year; likely $5000 soon
Equity interest that exceeds $20,000 or that exceeds 5% ownership interest in a publicly held entity; this threshold may also change soon
ANY interest in a privately held entity;
Any leadership position

5. Individual Obligations
Complete and submit an annual outside activities disclosure
Fulfills State of WI, UWS and Federal requirements
Revise the annual report whenever there is significant change in:
Outside activities or significant financial interests
Relationships with outside enterprises
Significant changes in research activities including sponsored research

6. UW COI Committee Responsibilities
Reviews all OAR submissions made on a yearly basis (~9500/y) and also any updates
Determines whether conflict situations exist that may require management (~500/y)
Assigns management using financial thresholds and consideration of nexus between university activities (federal funding and/or human subjects research) and outside activities (~400 active management plans)
Investigator interviews and committee experience contribute to assignments

7. Management Plans Provisions in a Management Plan include:
Disclose significant financial interests in publications and presentations
Disclose significant financial interests to students, staff, and co-investigators
Disclose proposed research support from any outside entity to the Dean’s Office
Obtain written facilities use agreements before use occurs
Have oversight of any purchases from outside entity
Complete annual review of management plan with Chair
***Provide timely updates of activities report***

8. Management Plans II
IF … you engage in Human Subjects Research, the following provision is included in your Management Plan:
Absent written approval from the COI Committee, you cannot serve as principal investigator (PI), co-investigator (co-PI), or key personnel for a human subjects protocol reviewed by a UW-Madison IRB if the outside entity:
sponsors the study, OR
owns or licenses a technology tested in the study

9. Exception? … Maybe
The COI Committee may grant you an exception to these restrictions on participation in human subjects research
Exceptions are ONLY granted for specific protocol
Your Dean’s Office must approve and submit an exception request on your behalf to the COI Committee
Very rare – may be granted if, for example, an individual is uniquely qualified by virtue of expertise or experience to participate in the research

10. Additional Information
Graduate School Office of Research Policy
UWS, State of WI and Federal Regulations
UW Conflict of Interest Committee