Topics Map > Research Policy and Compliance > Conflict of Interest (COI) and Outside Activities Reporting (OAR) > Individual Financial Conflict of Interest (FCOI)

Individual Financial Conflict of Interest: What to Report

This document provides a guide to what outside activities are reportable as individual significant financial interests.


Reportable Outside Financial Activities Non-Reportable Outside Financial Activities

Reportable compensation is any compensation given directly to you, your spouse, or your dependent children. However, it does not include money that is given through the University.

Some examples of reportable compensation include:

  • Salary, unless it falls into one of the non-reportable categories 
  • Spousal salary, if your spouse is employed in a field related to your institutional responsibilities 
  • Consulting fees
  • Gifts or other awards, including gifts-in-kind, honoraria, and participation in promotional activities
  • Income from editorial work (e.g., journal editorships). 
  • Payments connected to research, but are not governed by a research agreement between the sponsor and UW-Madison or the UW Medical Foundation.
  • Payments for serving on advisory boards
  • Royalty and copyright income not managed by the Wisconsin Alumni Research Foundation (WARF) or Wisconsin Center for Educational Products & Services (WCEPS).
  • Income from activities sponsored by a foreign institution of higher education or foreign governmental body
  • Travel reimbursements from businesses that exceed your actual travel costs
  • Compensation from activities NOT related to your institutional responsibilities at UW-Madison
  • Salary or other compensation from UW-Madison and affiliated entities (e.g., UW Hospital and Clinics, the VA Hospital, the UW Medical Foundation, and the Center for Advanced Studies in Business)
  • Royalty income from intellectual property that arose from University employment and that was assigned to organizations that were created to manage intellectual property on behalf of UW-Madison (e.g., WARF, WCEPS)
  • Income from invited seminars, lectures, and teaching engagements at U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutions that are affiliated with an institution of higher education as defined by 20. U.S.C. § 1001(a)
  • Payments under grant or gift agreements between the sponsor and the UW-Madison or the UW Foundation


Reportable Outside Financial Activities Non-Reportable Outside Financial Activities
  • Stock
  • Stock options
  • Sole proprietorships
  • Partnerships
  • Limited liability corporations
  • Ownership interests NOT related to your institutional responsibilities
  • Income from investment vehicles such as mutual funds and retirement funds is NOT reportable as long as you, your spouse, or dependent children do not directly control the vehicle or fund's investment decisions 
  • Interests in businesses or organizations that are unrelated to your institutional responsibilities 


Reportable Outside Financial Activities Non-Reportable Outside Financial Activities

Service in positions with fiduciary responsibility, which includes:

  • Executive positions, such as president, CEO, COI, etc. 
  • Senior management positions, such as president, treasurer, etc. 
  • Service on boards of directors 
  • Trusteeships
  • Professional societies

Non-reportable leadership positions do not relate to your institutional responsibilities or do not have fiduciary responsibilities and commonly includes religious organizations and political organizations.

Travel (PHS Only)

Reportable Outside Financial Activities Non-Reportable Outside Financial Activities

Investigators with PHS-funded research must report travel events, such as: 

  • Corporate-sponsored travel
  • Compensated vacation travel
  • Participation in a conference for a professional society
  • Travel sponsored by foreign institutes of higher education or foreign governmental agencies

For investigators with PHS-funded research, the following types of travel need not be reported:

  • Self-funded travel
  • Travel covered through University of Wisconsin-Madison e-Reimbursement system
  • Travel funded through the University of Wisconsin-Madison
  • Travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education (defined at 20 USC 1001(a) (, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. (The exception described here applies only to U.S.-based institutions and agencies.)
  • Travel reimbursed or sponsored by the National Research Commission or the related National Academies

Keywords:conflict of interest, outside activities report   Doc ID:32879
Owner:Samuel L.Group:VCRGE and Graduate School
Created:2013-08-19 15:29 CDTUpdated:2016-01-12 16:17 CDT
Sites:VCRGE and Graduate School
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