New federal regs on conflicts of interest

New Federal Regulations on Financial Conflicts of Interest take effect across the country on August 24, 2012. These changes require important adjustments to the ways that UW must report and manage financial conflicts of interest (COI). Please read below how these changes affect UW-Madison faculty and staff:

All individuals with a faculty appointment and all academic staff with an appointment of 50% or greater

  • Continue to file the annual Outside Activities Report (OAR) on-line upon request from the Provost, reporting all outside activities related to your institutional responsibilities (i.e., research, education, outreach, or administration).
  • Beginning August 24, 2012, if you have a new or increased outside financial interest, file an updated OAR within 30 days of the change.
  • If you are an investigator engaged in either federally funded or human subjects research, complete COI training via Learn@UW when you file your annual OAR in spring 2013 or when you submit a new PHS grant after August 24, 2012.

Public Health Service (PHS)-funded investigators

In addition to the above requirements, PHS-funded investigators (which includes all UW principle investigators, co-investigators and key personnel and also all investigators from outside of UW listed as subrecipients on PHS-funded proposals and awards managed by UW) must also comply with the following starting August 24, 2012:

  • Before a new or revised PHS proposal can be submitted, all investigators named on the PHS proposal will need to have a current OAR on file. Further details on UW procedures for submission of proposal including subrecipients is provided by Research and Sponsored Programs Notice 2013-1, which can be found at:
  • Before funds from newly awarded PHS grants can be spent, all investigators named on the PHS award will need to update their OAR and complete COI training via Learn@UW.
  • When an outside entity makes a payment directly to a PHS-funded investigator for travel, or pays for travel on behalf of that investigator, it must be reported within 30 days using the on-line OAR system. Types of travel that are excluded from this requirement are described here,

 Changes in definition of outside financial interests

  • Federal regulations now define $5000 as the threshold value for an outside financial interest requiring review by the UW-Madison COI Program.
  • Remuneration in excess of $5,000 from nonprofit organizations is no longer an exception to review.
  • Any ownership in a private company, regardless of value, requires review.

For more information, please visit or contact the UW-Madison COI Office at