Topics Map > Research Policy and Compliance > Conflict of Interest (COI) and Outside Activities Reporting (OAR) > Individual Financial Conflict of Interest (FCOI)
Frequently Asked Questions about Conflict of Interest
Outside Activities Reporting (OAR)
Review of OARs
1. What is a Conflict of Interest?
A Conflict of Interest (COI) exists when an investigator has a significant financial interest (SFI) 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 his/her immediate family. COIs represent a state of affairs, not behavior; frequently involve perceptions; and, are judged by others, not by those directly involved.
2. What is a Significant Financial Interest (SFI)?
A Significant Financial Interest (SFI) is a financial interest held by an individual or a business entity controlled or directed by the individual or a member of his or her immediate family that exceeds a certain threshold. The following thresholds are SFIs;
(1) remuneration received from an entity greater than $5,000 in 12 months;
(2) equity interest in a publicly held entity greater than $5,000 at the time of reporting;
(3) any equity interest in a privately held entity;
(4) royalty income from intellectual property rights that are not assigned to organizations created to manage such rights on behalf of the University of Wisconsin Madison;
(5) services in positions with fiduciary responsibility such as senior managers and members of boards of directors; and,
(6) for those that receive PHS funding, reimbursed or sponsored travel.
3. What is a Financial Conflict of Interest (FCOI)?
A FCOI exists when the UW Madison reasonably determines that an individual’s SFI is related to the individual’s federally funded research or human subjects research protocol and could directly and significantly affect the design, conduct or reporting of the research. See Conflict of Interest Policy
4. Who must complete an Outside Activities Report (OAR)?
All faculty, regardless of appointment, and all academic staff with a 50% or greater appointment at UW-Madison, as well as all individuals listed on human subjects protocols or federal grants, are required to fill out an Outside Activities Report (OAR) each year and whenever new outside activities are undertaken.
5. Why does UW-Madison require me to complete an OAR?
University of Wisconsin System Board of Regents policy Chapter 8 requires all faculty, regardless of appointment, and all academic staff with a 50% or greater appointment to file an OAR. In addition, there are federal regulations requiring OARs to be completed for individuals on federally funded grants and human subjects protocols.
7. What is reportable in your OAR?
All outside activities related to your institutional responsibilities, including your spouse's or immediate family's outside activities if they relate to your institutional responsibilities. Institutional responsibilities are individual's professional responsibilities on behalf of the University of Wisconsin Madison. These include all research, instruction, extension/outreach and administrative activities. Individual Financial Conflict of Interest: What to Report
8. What is the time period covered by an OAR?
The annual OAR asks you to report all outside activities from the previous calendar year. If you have changes in your outside activities, you must update and report your current activities up to that moment for the current calendar year.
9. How often will I be asked to complete an OAR?
Each year in the middle of January the Provost and the Associate Vice Chancellor for Research Policy will request that you complete your annual OAR. If you have any changes to your outside activities during the year, you are required to report those changes within 30 days. In addition, if you receive PHS funding, you will be asked to update your OAR no more than 30 days after Research and Sponsored Programs (RSP) begins award setup.
10. When is it appropriate for me to report updates to my OAR?
Faculty and academic staff are responsible for updating their reports anytime there is a relevant change in their outside activities (e.g. new relationships with outside organizations or increased compensation for an on-going activity). An updated version of the outside activity report may be completed at any time during the year by logging back into the Outside Activity Report.
11. What should I do when a relationship with an outside activity has ended?
Update your OAR to record the end date of the activity. You may log back into your Outside Activity Report. If you have a Management Plan for the activity that has ended, please notify the COI Program and they will terminate your Management Plan.
12. What information do I need to file my OAR?
You need the name of each outside entity and how much money you received from them. Having your 1099 tax forms handy may be helpful. If you have stock in a company, you will need to know approximately how much it is worth at the time you file your OAR. Sometimes if it is a privately held company, you may not know the exact value. You will be given the opportunity to report that the value is unknown.
13. Can I file an OAR for another person?
No. Each individual must log in with their own NetID and password to file an OAR. In addition, you must certify that all of the information is accurate before submitting your OAR.
14. Who can you contact if you need assistance filing your OAR?
Please use this link to find your School, College or Division contact regarding OARs. Individual Conflict of Interest: Who to Contact for Assistance If you need additional help, please contact the COI Program at firstname.lastname@example.org or call Sam Leinweber (608) 890-4603 or Stephanie LeRoy at (608) 890-4460.
15. Do I have to report travel in my OAR?
If you receive any funding from PHS, you must report travel on your OAR. If you do not receive funding from PHS, you will not be asked the travel questions.
16. What type of travel must be reported?
Any sponsored or reimbursed travel must be reported on your OAR. If your travel is paid through the UW’s e-reimbursement system, you do not need to report it.
17. When reporting travel, what information do I need to include?
The required information is (1) the entity funding the travel, (2) the destination, (3) the duration, and (4) the purpose of the travel. You do not need to know the amount paid by the sponsor.
18. Who reviews the Outside Activities Report (OAR) after they are submitted?
Colleges, schools, divisions, departments, and units share responsibility for reviewing reports. Reviewers contact individuals to resolve any completeness issues with reports. They will also address conflict of commitment issues with individuals.
19. What is the role of the Conflict of Interest Committee?
The Conflict of Interest Committee, made up of faculty members from across campus, reviews the outside activity reports of faculty and academic staff for possible financial conflicts of interest. The Committee then works to eliminate, minimize, or manage any actual or potential conflicts of interest identified by the reporting process.
20. What is a management plan?
A Management Plan is a way to address an FCOI to ensure, to the extent possible, that the design, conduct and reporting of research will be free from bias.
A Management Plan may minimize or eliminate the FCOI. Financial Conflict of Interest Management Plan Example
21. Who is subject to a management plan?
Any individual for whom the COI Committee has determined a FCOI exists must have a Management Plan in place.
22. I was assigned a management plan, what should I do next?
There are 3 things to do at this time. First, follow the instructions in the email to log back into your OAR and agree to the Management Plan. Second, schedule a meeting with your Chair or Director to make them aware of your Management Plan and to discuss the requirements of the plan. Lastly, draft a notification letter to your staff and students to inform them of your outside activity. You will receive an email outlining these steps when a Management Plan is issued by the COI Committee.
23. Who must I notify about my management plan?
As required under your Management Plan, you must notify all staff and students that you supervise in your research of your outside activities. You must also notify co-Investigators of the existence of your Management Plan. A sample notification letter is contained in the Management Plan. You may also draft your own letter following the guidelines in the plan.
24. What happens if I disagree with the requirement for a management plan?
If you disagree with the assignment of a Management Plan, you may make a written request of reconsideration by contacting your school or college's Dean's Office. While reasonable efforts will be made to process your appeal as expeditiously as possible, please note that the appeal process may delay spending on PHS awards.
25. What happens once I have ended a relationship with an entity for which I have been assigned a management plan?
You must update your OAR to report the end of the relationship. The COI Committee will review your updated OAR and likely terminate your Management Plan. Please note the relationship must really be ended and not just a project completed with more to come.
26. May I request a management plan?
Yes. If you believe there is a potential for a COI to exist between your outside activity and your research, you do not need to wait for the COI Committee to review your OAR. You may proactively request a Management Plan through your Dean’s Office.
27. How does my management plan impact protocol submission?
If you have a Management Plan, your protocol submission may be affected. Absent written approval from the COI Committee, you cannot serve as principal investigator (PI), co-investigator (co-I), or key personnel for a human subjects protocol reviewed by a UW-Madison IRB if the entity which has been assigned a Management Plan: a) sponsors the study, or b) owns or licenses a technology tested in the study. You may work with you Dean’s Office to apply for an exception to this provision.
28. How do I apply for an exception to my Management Plan?
You must work with your Dean’s Office to request an exception from the COI Committee. For more information see Financial Conflict of Interest Policy and Procedures: Guidance Document
29. What is the Online COI Training Course?
It consists of 5 modules covering the UW Madison Conflict of Interest Policy and its requirements. There is a 1 question quiz at the end.
30. Do I have to complete the Online COI Training Course?
If you receive federally funded awards or are conducting human subjects research, you must complete the COI Training course at least once every 4 years.
31. How do I access the Online COI Training Course?
32. Once complete, how long do the results take to appear in the Training Lookup Tool?
The results can take up to 24 hours to appear in the Training Lookup Tool. If you need the results before then, please contact the COI Program and they can provide real time information.
33. What is a subrecipient for purposes of completing an Outside Activity Report (OAR)?
A sub-recipient is an entity or individual named on a subcontract from the UW Madison on a federally funded award or human subjects research proposal.
34. What is the first step I need to take as a subrecipient?
If you do not have your own PHS compliant COI Policy, you must follow the UW Madison’s COI Policy. This means you must file an OAR and take the COI Training course. In order to do so, you will need a UW NetID and password. The UW Conflict of Interest Program will assist you in obtaining a NetID from the UW Department of Information Technology. To request a NetID, please click Subrecipient NetID.
35. As a sub-recipient, what are my responsibilities regarding submission of an OAR?
Under the UW Madison’s COI Policy you must submit an online OAR. You will need a UW NetID and password to access the online OAR form. Outside Activity Report
36. As a sub-recipient, what are my responsibilities with respect to COI Training?
The UW Madison’s COI Policy requires you to complete the online COI Training course. You will need a UW NetID and password to access the COI Training course. For more information please see Conflict of Interest Training CourseTop
37. If I am on a PHS grant, what are my COI related responsibilities for award setup?
If you receive a Notice of Award for a PHS funded grant, you will need to do 2 things. First, you must have a recently updated OAR on file. If you have not filed an OAR in the past 30 days, you will need to file an Outside Activity Report even if nothing has changed. Second, you must take the COI Training course if you have not completed the course. You may access the course at Learn@UW.
37. Where can I go for more information about COI and award setup?
Research and Sponsored Programs has additional information on award setup.