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Policy

To ensure that UW-River Falls grant-funded researchers do not have external financial interests which would conflict with or bias the results of their research.

New federal rules require universities receiving grants from the National Science Foundation and Public Health Service to have in place a Conflict of Interest/Financial Disclosure policy by October 1, 1995. This paper establishes such a policy for UW-River Falls.

Authority

The UW-River Falls Chancellor issues this policy in accordance with the Administrative Policy process.
The VCAF is responsible for the administration of this policy. Request an exception to this policy by writing to administrative-policy@uwrf.edu.

Sanctions and Appeals Process

Failure to adhere to the provisions of this policy may result in appropriate disciplinary action as provided under existing procedures applicable to students, faculty, and staff, and/or civil or criminal prosecution.

Procedure

1. The Director of Grants and Research will attach the newly created Financial Disclosure Statement for Grant-Funded Research form (attached) to the existing Approval to Apply for External Funding form. All investigators involved in a grant proposal must complete and sign this form before the university submits their proposals to the funding agency. The Director will review the modified forms.
   
2. If an investigator has responded negatively to the conflict of interest questions on the Financial Disclosure Statement, the Director will submit the grant proposal to the funding agency and file the form. If an investigator has responded positively to the conflict of interest questions, the Director will submit the proposal to the funding agency and then refer it to a Conflict Review Committee consisting of the Director, the Dean of the investigator's college or unit, and one faculty representative from the Institutional Studies, Research, and Grants Committee. That Conflict Review Committee will study the facts of the case, meet with the proposer to solicit possible remedies which will eliminate any actual or potential conflicts of interest, and propose one of three resolutions:
   a. Accept the grant award (if it is funded).
   b. Decline the grant award.
   c. Accept the grant award subject to suitable modifications in the award document or in the investigator's affiliation with the external organization involved. Such modifications might include:
   - Making public disclosure of the investigator's financial interests.
   - Review of data and research results by in-house or external independent reviewers identified by the committee and the investigator.
   - Modification of the research plan to eliminate the possibility of conflict of interest.
   - Disqualification of the investigator from participation in a portion of the research.
   - Divestiture of significant financial interests.
   - Severance of relationships that create actual or potential conflicts.
   If the investigator is satisfied with the Conflict Review Committee's proposed resolution, it will stand. If s/he is dissatisfied with the Conflict Review Committee's proposed resolution, s/he may appeal to the Provost and Vice Chancellor who will consult with the applicant and Conflict Review Committee as deemed necessary and appropriate to the particular circumstance. The decision of the Provost and Vice Chancellor shall be final.
   
3. Violations of this policy, such as willful concealment of financial interests or failure to comply with agreed-upon modifications to manage, reduce or eliminate financial interests, may result in sanctions being imposed upon the violating individual in accordance with UW-River Falls personnel policies and procedures.
   
4. The Grants Office shall maintain records pertaining to each disclosure. Access to such records will be limited to the applicant(s), the Conflict Review Committee, the Provost & Vice Chancellor and others who have a legal right to review the records. Certain sponsors, particularly federal agencies, may have requirements that differ from this policy with regard to the timing and frequency of disclosures and other conflict considerations. In the case of such discrepancies, the sponsors' requirements will generally prevail.
   
5. Collaborators from other institutions must either comply with this policy or provide certification that their institutions are in compliance with federal policies regarding financial disclosure/conflict of interest and that their portion of the project is in compliance with their institutional policies.

University Responsibilities

The Director of Grants and Research shall be responsible for implementing, publicizing and administering this policy.

Department/Unit Responsibilities

Departments and units (and their members) are responsible for adhering to the policy.

Background

In recent years, several scandals have emerged which call into question the ethics of some academic scientists. For instance, researchers investigating the efficacy of new drugs have been found to be very well-paid consultants to the pharmaceutical companies which had invented the new drugs and proposed them for FDA approval. In the face of Congressional pressure, the Public Health Service and the National Science Foundation created new rules governing conflict of interest and financial disclosure which will prevent such abuses. Early versions of those rules were proposed in 1994. After comment and reconsideration, final rules were published in the Federal Register on July 11, 1995 (vol. 60, no. 132, pp. 35809-35819; editorial corrections appear in the July 31 issue).

Chapter UWS 8 of the Wisconsin Administrative Code currently serves as the Code of Ethics for unclassified staff. It requires unclassified staff to report significant outside activities and interests each year. Those requirements are unchanged by this policy paper. UWS legal counsel has determined that UWS 8 is not sufficient to meet the new rules. Consequently UW institutions must implement a policy in accord with the new rules; hence this UW-River Falls policy paper.

Contact

Please direct questions about this policy to administrative-policy@uwrf.edu.