Vice Chancellor for Administration and Finance Home

Administrative Policies

AP 1 State Telephone System and Cellular Telephone Sets

AP 2 Telecommunications Equipment (Voice)

AP 3 Smoking

AP 4 Safety and Health

AP 5 Risk Management Policy

AP 6 Parking Regulations

AP 7 Sign Posting Policy

AP 8 Chargeback of Physical Plant Services

AP 10 Building Keys

AP 11 Fleet Vehicles

AP 12 Records Hold Policy

AP 13 Dispensing of Hearing Aids

AP 14 Policy on Business Activities

AP 15 Dangerous Weapons on Campus

AP 16 Collection of Indirect (Overhead) Costs

AP 17 Distribution of Indirect (Overhead) Costs

AP 18 Seat Belt Use

AP 19 Use of University Facilities

AP 20 Athletic Camps and Clinics

AP 21 University-Foundation Relationships

AP 22 Employee Accident/Injury Procedures

AP 23 Naming of Rooms and Buildings on Campus

AP 24 Postal Policy

AP 25 Requirement for a Mandatory Residential Dining Plan

AP 26 Requirement for Mandatory Housing

AP 27 Records Management Program

AP 29 Bad Check Policy

AP 30 In-Line Skates and Skateboarding

AP 31 Computer Software Use

AP 32 Inclement Weather Practice

AP 33 International Student Tuition Remission Policy

AP 36 Information Security

AP 37 Conflict of Interest/Financial Disclosure Policy

AP 38 Health Insurance Requirement for International Students

AP 39 Reuse Policy for Replaced Computers

AP 40 Alcohol Beverages on Campus

AP 41 Computer Replacement Policy

AP 42 Outreach Residual Funds

AP 43 Summer Session and J-Term

AP 44 Use of Copyrighted Material

AP 45 Shared Radio Spectrum Management and Coordination

AP 46 Emeriti Status for Unclassified Staff (Faculty/Academic Staff)

AP 47 Honored Retiree Status for Classified Employees

AP 48 Application for Immigrant Visas

AP 49 Determination of Outreach Course

AP 50 Cellular Telephone Policy

AP 52 Access, Use, and Retention of Social Security Numbers

AP 53 Full-time Status with a Reduced Course Load

AP 54 Advertising, Sponsorship, and Promotion of Alcohol and/or Tobacco Products on Campus

 

University of Wisconsin-River Falls Administrative Policy Paper
Number: AP 37 Revised
Date Issued: November 2, 1998
Subject: Conflict of Interest/Financial Disclosure Policy

1.0 POLICY/PURPOSE:

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.

2.0 OVERVIEW/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 unclassifed 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.

3.0 UNIVERSITY RESPONSIBILITIES:

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

4.0 DEPARTMENT/UNIT RESPONSIBILITIES:

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

5.0 PROCEDURE:

5.1 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.
5.2 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:
1. Accept the grant award (if it is funded).
2. Decline the grant award.
3. 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 & 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 & Vice Chancellor shall be final.
5.3 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.
5.4 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.
5.5 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.

 

 

---

Financial Disclosure Statement for Grant-Funded Research

Each investigator (i.e., each person who is responsible for the design, conduct, or reporting of research as part of the proposed project) must complete a form.

Consult the definitions of financial (below) interest and a formula to follow to determine what must be reported.

Name: ______________________________

Dept: ______________________________

Title of grant proposal:   ______________________________

_____   _____	I have no significant financial interests to report. I and/or my immediate family receive or expect to receive payments totaling $5,000 or more per year from a single for-profit business enterprise that would reasonably appear to be directly and significantly affected by my research or educational activities which are funded or may be funded by federal agencies.
	Name of entity Making Payments	Type of Payment (Salary, Dividend, Royalty, etc.)	Amount of Payment
	________________ ________________ ________________	________________ ________________ ________________	________________ ________________ ________________
_____	I and/or my immediate family have ownership interests of 5% or greater in a single for-profit business enterprise that would reasonably appear to be directly and significantly affected by my research or educational activities which are funded or may be funded by federal agencies.
	Name of entity Making Payments	Type of Payment (Salary, Dividend, Royalty, etc.)	% of Interest
	________________ ________________ ________________	________________ ________________ ________________	________________ ________________ ________________

I hereby certify that, to the best of my knowledge, the above information is correct.

Signature: _______________________________________

Date: ________________

---

Types of interest that are reportable unless exempt under Section III:

Anything of monetary value that you and/or your immediate family received from for-profit businesses, including but not limited to:

• salaries or other payments for services (e.g. consulting fees or honoraria)
• equity interests (e.g. stocks, stock options, or other ownership interests)
• intellectual property rights (e.g. patents, copyrights, and royalties from such rights, including books if published by commercial presses)

Types of interest that are not reportable:

• salaries, royalties, or other payments from UW-River Falls
• income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities
• payments from advisory committees or review panels for public or nonprofit entities
• payments from a single business if the entire amount of payments you and your immediate family together received is less than $5,000.
• ownership interest in a business if you and your immediate family's ownership interest in the business together represent less than 5% of the total ownership interests in the business.

Formula to determine whether a financial interest is reportable:

Step 1.	Do you and/or your immediate family have a financial interest from or in a for-profit business that is reasonably likely to be directly and significantly affected by the research or educational activities for which you have received or expect within the year to seek and receive funding? If not, then the interest is not reportable. If yes, go to step 2.
Step 2.	Do you and/or your immediate family together receive from such a business $5,000 or more per year, or is the ownership interest you and your family have together in such a business 5% or more of the total ownership interest? If no, then the interest is not reportable. If yes, you must report the interest(s) on the other side of this form.

 

University of Wisconsin - River Falls
410 South Third Street River Falls, WI USA 54022-5001 (715)425-3911
Copyright © 1995-2008 University of Wisconsin-River Falls