Financial Conflict of Interest (FCOI)

June 1, 2012

I. Policy

The use of participant incentives is a common research practice. It encourages and recognizes human subjects' participation in and completion of a research task or sequence of tasks, and it may be key to securing broad participation in a research protocol. Incentives may include cash, checks, and gift cards. The University of Wisconsin-Eau Claire balances its responsibility to maintain the confidentiality of information about human research subjects with record-keeping requirements of the University of Wisconsin System, grantor agencies, and the Internal Revenue Service. In situations where confidentiality is not related to human subjects but it is in the best interests of the study to maintain confidentiality, the same procedures outlined below will apply.

The overarching aims of this policy are to ensure:

• The confidentiality of research participants.
• Timely, convenient compensation to participants to facilitate the progress of the study.
• The appropriateness of the incentive for participation in the research study.
• Compliance with relevant institutional, governmental, and grantor policies and practices.

Please view the complete Policy on Research Participant Incentives as well as Sample Forms.

There are a number of activities that have potential export control implications:

• Traveling abroad
• Shipping items abroad
• Working with foreign collaborators, whether in the United States or overseas
• Working with controlled items (examples include lasers, thermal imaging cameras, select agents, space qualified equipment and encryption
• Working with a grant or other contract that has an export control clause, publication restriction or personnel restriction
• Doing any work with a person, business or organization that is a citizen of or headquartered in Iran, Syria, Sudan, North Korea, Cuba, or the Crimea

If you have doubts about whether an activity falls within export control, please contact the Office of Research and Sponsored Programs

International Traffic in Arms Regulations (ITAR) – The ITAR are overseen by the Department of State. They regulate military items and information. Items regulated under the ITAR can be found in the U.S. Munitions List (22 CFR 121) and include naval vessels, ordnances, military jets, tanks, their software, components and accessories.

Export Administration Regulations (EAR)– The EAR are overseen by the Department of Commerce. They regulate dual use items and information. Dual use items are commercial items that could be used for military, terrorism, nuclear proliferation or similar purposes. The items regulated under the EAR can be found in the Commerce Control List (15 CFR 774 – Supplement No. 1), and include items such as lasers, telecomm equipment, IR sensors, computers, electronic test equipment, encryption, their software, components and accessories.
https://www.bis.doc.gov/index.php/regulations/export-administration-reg…

Foreign Asset Control Regulations (FACR) – The FACR are overseen by the Office of Foreign Asset Controls (OFAC) in the Department of Treasury. They regulate assets, persons and organizations. These regulations are not concerned so much with what is being shipped, but rather where and to whom it is being shipped.

Embargoed  and Restricted Countries
This is a list of the embargoed and restricted countries per the United State's government and trigger a higher level of risk with activities.

While the regulations above are the key Export Control regulations, other government agencies, such as the Departments of Defense and Energy have additional regulations that may impact specific research projects.

Exports include a wide variety of things beyond simply putting something in a box and sending it abroad. An export can include any of the following:

• Shipping an item overseas
• Sending an e-mail to a foreign person
• Making a phone call or sending a fax to a foreign person
• Any electronic transfer of information abroad
• Deemed exports

Deemed exports occur any time a foreign person gains access to information, data or technology in the United States. At that point it is deemed to have been exported to their country of citizenship.
Examples of deemed exports include:

• Foreign persons working in a lab
• Sharing information with a foreign person in the United States regarding a project
• Taking foreign persons on a tour of a lab with controlled equipment
• Speaking with foreign collaborators at conferences being held in the United States

A foreign person is anyone who is NOT:

• A U.S. citizen
• A permanent resident/green card holder
• Someone granted asylum, refugee status or amnesty by the government
• A US company, university, organization or government division

Please remember, green card holders are U.S. persons, whereas persons here on work or student visas are Foreign Persons.  Additionally, foreign students of any level are counted as foreign persons for export control purposes.

The Fundamental Research Exemption states that an export license is not required to transfer fundamental research to foreign persons. Fundamental research is defined as information, technology or software generated from research at an institute of higher learning the results of which are ordinarily published. Most research conducted at UW–Eau Claire falls under this exemption.

Three things are important to remember with this exemption, however:

1. The resulting information may be exempt from export controls, but the equipment used in that process may still be controlled and require an export control analysis.
2. A publication restriction (in the project award) can negate this exemption as it is seen as hampering the researcher's ability to publish their results.
3. Non-disclosure agreements (NDA) may restrict the researcher's ability to publish technical information covered by the NDA. Please contact the Export Control Office prior to signing a NDA to determine the impact it may have on your project.

Licenses are required when no exemption can be found for a research activity, particular item or specific person in regards to a project.  The need for a license will depend upon the commodity being shipped, its destination country and/or the person/organization receiving the item.  It generally takes 1-2 months to submit and receive a license from the Departments of State and Commerce. Licenses from the Department of Treasury may take considerably longer. 

Here is a glossary of common terms and acronyms that you will commonly run across in export control.

1. BIS (Bureau of Industry Security) – The agency in the U.S. Department of Commerce that manages and enforces the EAR.
2. CCL (Commerce Control List) – The list of items export controlled under the EAR. The items in this list are typically Dual Use items.
3. Commodity Classification – A determination submitted to the Commerce Department to determine under which ECCN a particular item, technology or software is controlled.
4. Commodity Jurisdiction – A submission to the State Department to determine whether a particular item, technology or software falls under the control of the ITAR or the EAR.
5. DDTC (Directorate of Defense Trade Controls) – The agency in the U.S. Department of State that manages and enforces the ITAR.
6. Deemed Export – The transfer of technical information, data or software to a foreign person within the United States. It is deemed to be an export to that person’s home country.
7. Dual Use – Commercial items with potential military or national security applications.
8. E:1/E:2 Countries – Countries that are the most highly restricted/embargoed by the U.S. government due to terrorism or national security reasons. The most up to date list can be found here.
9. EAR (Export Administration Regulations) – The export control regulations administered by the U.S. Department of Commerce that controls dual use items, information, data and software.
10. EAR99 – Items that are subject to the EAR, but not controlled under the EAR’s export control categories (ECCNs). EAR99 items are only controlled to restricted/embargoed countries or restricted parties.
11. ECCN (Export Control Classification Number) – A category in the CCL that defines the items, materials, software and technology that are controlled, the extent to which they are controlled and the license exceptions available. There are 10 category groupings.
12. Export – Sending or taking anything out of the United States in any manner, including shipping, verbal (i.e., telephone) or electronic (i.e., e-mail, webcasts, social media, fax).
13. Foreign Person – A person that is not a U.S. Person. This also includes foreign organizations and governments.
14. Fundamental Research – Research in engineering, technology, science or mathematics the results of which are intended for publication or communicated widely within the research community. Fundamental research is not subject to restrictions.
15. ITAR (International Traffic in Arms Regulations) – The export control regulations administered by the U.S. Department of State that controls military, national security and space items, information, data and software.
16. NLR (No License Required) – A determination that a particular activity (i.e., shipping an item or discussing a research collaboration) does not require an export license to proceed. This is typically because the applicable item or information is not export controlled, an exemption/exception applies to the activity, the activity is not with a country where the activity requires a license or the activity is not with a party for which a license is required.
17. NDA (Non-Disclosure Agreement) – A document between two or more parties agreeing to not communicate private, proprietary, confidential, patentable and/or controlled information or data to persons not included as part of the agreement.
18. OFAC (Office of Foreign Asset Controls) – The agency in the U.S. Department of Treasury that manages and enforces the Foreign Asset Control Regulations.
19. Personnel Restriction – A clause placed in an agreement or award that restricts persons from certain or all foreign countries from participating in the research. Research subject to a personnel restriction is typically not considered fundamental research.
20. Publication Restriction – A clause placed in an agreement or award that restricts the researcher from publishing his/her research until the sponsor or some other party approves the content of the research article. The approver can alter or remove content, methodology or results from the proposed article.  Research subject to a publication restriction is not fundamental research.
21. Publication Review - A clause placed in an agreement or award that allows the sponsor or some other party to review a proposed research article for confidential, proprietary, patentable or private information. It is not an approval and does not impact the publication of the results of the research.  Publication review periods of 30-90 days are typically considered acceptable.
22. Public Domain – Information that is readily available in libraries, magazine/newspaper articles, conference proceedings and/or on-line.
23. RPS (Restricted Party Screening) – The activity of determining whether a person, company, organization, or vessel (i.e., a party) is on any government lists that places restrictions on activities with that party. RPS usually applies to the use of an on-line tool to conduct the determination.
24. RWA (Returned Without Action) – This is a designation for an EAR export license that has been returned to the applicant either because of insufficient information or a license is not required.
25. Service – Work done for hire that is not considered research.
26. Subject to the EAR – Items that are controlled under the EAR. Fundamental research, information in the public domain and mass media items such as books, magazines and musical recordings are NOT subject to the EAR.
27. TCP (Technology Control Plan) – A written plan that spells out the security measures needed for a particular project to ensure compliance with the appropriate export control regulations. The TCP may include computer password protection, encryption of data, physical locks on equipment, limiting access to labs through locks/key cards and lock boxes for materials depending upon the needs of the project/lab.
28. USML (United States Munitions List) – The list of items export controlled under the ITAR. This list contains military, national security and space items.
29. U.S. Person – A person that is a citizen, national or permanent resident of the U.S., or granted asylum, amnesty or refugee status by the U.S. government. This includes U.S. governments and universities, and companies organized under U.S. law.

Cuba, Iran, North Korea, and Syria

The most up to date list can be found at the link below:

E:1/E:2 Countries

I. Policy

Consistent with federal regulations, beginning on August 24, 2012, all faculty and academic staff at the University of Wisconsin-Eau Claire who plan to participate in, or are participating in, Public Health Service (PHS)-funded research must fully disclose potential financial conflicts of interest and successfully complete financial conflict of interest training. The purpose of this policy is to comply with PHS regulations on the Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94). These regulations promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under PHS grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest.

II. Procedures

A.  Disclosure
According to the National Institutes of Health, a potential financial conflict of interest exists when an investigator has significant financial interests 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 or her immediate family (i.e., spouse and dependent children). As a result, all faculty and academic staff who plan to participate in, or are participating in, PHS-funded research must submit a Financial Conflicts of Interest Disclosure Form no later than at the time of application, within 30 days of discovering or acquiring a new significant financial interest, and at least annually during the period of award.

Examples of significant financial interests that must be disclosed include the following:

• When the value of any remuneration received from an entity in the twelve months preceding the disclosure and the value of any equity interest (e.g., stocks, stock options, or ownership interests) in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
• When any equity interest in a non-publicly traded entity is held.
• Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
• Any reimbursed or sponsored travel (i.e., paid by an outside entity directly to a provider on behalf of the investigator) that is related to institutional responsibilities.

Significant financial interests do not include the following types of financial interests:

• Salary, royalties, or other remuneration paid by UW-Eau Claire to the investigator if the investigator is currently employed or otherwise appointed by UW-Eau Claire, including intellectual property rights assigned to UW-Eau Claire and agreements to share in royalties related to such rights;
• Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles;
• Income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education;
• Income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to PHS-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a management plan, including appropriate compliance monitoring.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, including discipline, loss of privilege to serve as an investigator on PHS-funded research projects, and dismissal. Instances of noncompliance trigger obligations for UW-Eau Claire to conduct a retrospective review of the research conducted during the period of noncompliance to ensure that it was not biased in its design, conduct, or reporting. If bias is found, the sponsor must be notified and a mitigation report submitted. Financial conflict of interest reports must be submitted annually thereafter.

If the NIH determines that one of its funded clinical research projects whose purpose is to evaluate the safety or effectiveness of a drug, medical device or treatment has been designed, conducted or reported by an investigator with a financial conflict of interest that was not managed or reported by UW-Eau Claire, the investigator involved will be required to disclose the financial conflict of interest in each public presentation of the results of the research and to request an addendum to previously published presentations.

Information concerning financial conflicts of interest held by investigators will be made accessible consistent with federal regulations. Records relating to all investigator disclosures of financial interests and UW-Eau Claire’s review of, or response to, such disclosures (whether or not a disclosure resulted in a financial conflict of interest determination), and all actions under UW-Eau Claire’s policy or retrospective review, if applicable, will be maintained for at least three years from the date the final expenditures report is submitted.

B. Training
The investigator is responsible for successfully completing financial conflict of interest training on the federal regulation, on disclosure responsibilities, and on this UW-Eau Claire policy prior to engaging in PHS-funded research and at least every four years thereafter. Investigators who come to UW-Eau Claire from other institutions must undergo UW-Eau Claire’s training prior to the expenditure of funds on a PHS-funded research project. Should UW-Eau Claire find that an investigator is not in compliance with the policy or a financial conflict of interest management plan, retraining will be necessary. In the event UW-Eau Claire revises its financial conflict of interest policy and procedures in any manner that affects the requirements of investigators, retraining will be necessary.

Instructions for completing HSP Training via CITI:

Visit the CITI training website: https://about.citiprogram.org/en/homepage/
Create an account using your UWEC email address
Click "ADD a Course" in the "My Learner Tools for University of Wisconsin-Eau Claire"
Choose the appropriate course-Conflicts of Interest (COI)

Complete all modules required for your course. Successful completion requires a composite score of 80% on the quizzes. Quizzes may be repeated in order to achieve this score. A completion report will be generated when all modules are complete and a composite score of 80% has been achieved.

C. Treatment of Subcontractors, Subrecipients, and Collaborators
When UW-Eau Claire carries out a PHS-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict of interest management and reporting in the agreement between the parties.

Last updated: November 3, 2023

III. Definitions

The PHS regulations provide the following key definitions of terms.

• Disclosure of significant financial interests means an Investigator's disclosure of significant financial interests to an Institution.
• Financial conflict of interest (FCOI) means a significant financial interest that could directly and significantly affect the design, conduct, or reporting of PHS-funded research.
• FCOI report means an Institution's report of a financial conflict of interest to a PHS Awarding Component.
• Financial interest means anything of monetary value, whether or not the value is readily ascertainable.
• HHS means the United States Department of Health and Human Services, and any components of the Department to which the authority involved may be delegated.
• Institution means any domestic or foreign, public or private, entity or organization (excluding a Federal agency) that is applying for, or that receives, PHS research funding.
• Institutional responsibilities means an Investigator's professional responsibilities on behalf of the Institution, and as defined by the Institution in its policy on financial conflicts of interest, which may include for example: activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
• Investigator means the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding, which may include, for example, collaborators or consultants.
• Manage means taking action to address a financial conflict of interest, which can include reducing or eliminating the financial conflict of interest, to ensure, to the extent possible, that the design, conduct, and reporting of research will be free from bias.
• PD/PI means a project director or principal Investigator of a PHS-funded research project; the PD/PI is included in the definitions of senior/key personnel and Investigator under this subpart.
• PHS means the Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health (NIH).
• PHS Awarding Component means the organizational unit of the PHS that funds the research that is subject to this subpart.
• Public Health Service Act or PHS Act means the statute codified at 42 U.S.C. 201 et seq.
• Research means a systematic investigation, study or experiment designed to develop or contribute to generalizable knowledge relating broadly to public health, including behavioral and social-sciences research. The term encompasses basic and applied research (e.g., a published article, book or book chapter) and product development (e.g., a diagnostic test or drug). As used in this subpart, the term includes any such activity for which research funding is available from a PHS Awarding Component through a grant or cooperative agreement, whether authorized under the PHS Act or other statutory authority, such as a research grant, career development award, center grant, individual fellowship award, infrastructure award, institutional training grant, program project, or research resources award.
• Senior/key personnel means the PD/PI and any other person identified as senior/key personnel by the Institution in the grant application, progress report, or any other report submitted to the PHS by the Institution under this subpart.

Significant financial interest means:
(1) A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's institutional responsibilities:

(i) With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;

(ii) With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator's spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); or

(iii) Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.

(2) Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities; provided, however, that this disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education. The Institution's FCOI policy will specify the details of this disclosure, which will include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration. In accordance with the Institution's FCOI policy, the institutional official(s) will determine if further information is needed, including a determination or disclosure of monetary value, in order to determine whether the travel constitutes an FCOI with the PHS-funded research.

(3) The term significant financial interest does not include the following types of financial interests: salary, royalties, or other remuneration paid by the Institution to the Investigator if the Investigator is currently employed or otherwise appointed by the Institution, including intellectual property rights assigned to the Institution and agreements to share in royalties related to such rights; any ownership interest in the Institution held by the Investigator, if the Institution is a commercial or for-profit organization; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education; or income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.

The National Science Foundation (NSF) requires the University of Wisconsin-Eau Claire to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced, or eliminated prior to the expenditure of the award funds. If an institution carries out agency-funded research through subawardees, contractors, or collaborators, the institution must take reasonable steps to ensure that the collaborating entity has its own policies in place that meet the requirements of this policy or that investigators working for such entities follow the policies of the primary institution.

NSF requires that each investigator disclose to a responsible representative of the institution all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF or in entities whose financial interests would reasonably appear to be affected by such activities. NSF requires UW-Eau Claire to ensure that investigators have provided all required financial disclosures at the time the proposal is submitted to NSF. Disclosures must be updated during the period of the award, either on an annual basis or as new reportable significant financial interests are obtained.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to NSF-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a plan to manage, reduce or eliminate conflicts of interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of NSF-funded research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to: public disclosure of significant financial interests; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in the portion of the NSF-funded research that would be affected by significant financial interests; divestiture of significant financial interests; or severance of relationships that create conflicts.

If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, such as discipline, loss of privilege to serve as an investigator on NSF-funded research projects, and dismissal. UW-Eau Claire must keep NSF’s Office of the General Counsel appropriately informed if the institution finds that it is unable to satisfactorily manage a conflict of interest. Grantee notifications of conflict of interest that cannot be managed, reduced, or eliminated and awardee notifications of situations where research will proceed without the imposition of conditions or restrictions when a conflict of interest exists, must be signed and submitted by the Executive Director for Research via use of NSF’s electronic systems.

UW-Eau Claire must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any NSF action involving those records, whichever is longer.

Treatment of Subcontractors, Subrecipients, and Collaborators

When UW-Eau Claire carries out a NSF-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict of interest management and reporting on the agreement between the parties.

Last updated: November 3, 2023

The term “investigator” means the principal investigator, co-principal investigators/co-project directors, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by NSF.

As specified by NSF, the term “significant financial interest” (SFI) means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options, or other ownership interests); and intellectual property rights (e.g., patents, copyrights, and royalties from such rights).

The term does not include:

·         salary, royalties, or other remuneration from the applicant institution

·         income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities

·         income from service on advisory committees or review panels for public or nonprofit entities

·         an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity

·         salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the twelve month period

NOTE: Although current NSF regulations specify a higher threshold for SFI, UW-Eau Claire policy identifies $5,000 as the monetary threshold. Similarly, in non-publicly traded companies, UW-Eau Claire policy identifies any equity amount as the threshold.

Last Updated: January 2024

The National Aeronautics and Space Administration (NASA) requires the University of Wisconsin-Eau Claire to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced, or eliminated prior to the expenditure of the award funds. If an institution carries out agency-funded research through subawardees, contractors, or collaborators, the institution must take reasonable steps to ensure that the collaborating entity has its own policies in place that meet the requirements of this policy or that investigators working for such entities follow the policies of the primary institution.

NASA requires that each investigator disclose to a responsible representative of the institution all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by NSF or in entities whose financial interests would reasonably appear to be affected by such activities. NASA requires UW-Eau Claire to ensure that investigators have provided all required financial disclosures at the time the proposal is submitted to NASA. Disclosures must be updated during the period of the award, either on an annual basis or as new reportable significant financial interests are obtained.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to NASA-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a plan to manage, reduce or eliminate conflicts of interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of NASA-funded research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to: public disclosure of significant financial interests; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in the portion of the NASA-funded research that would be affected by significant financial interests; divestiture of significant financial interests; or severance of relationships that create conflicts.

If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, such as discipline, loss of privilege to serve as an investigator on NASA-funded research projects, and dismissal. UW-Eau Claire must keep NASA’s Grant Officer appropriately informed if the institution finds that it is unable to satisfactorily manage a conflict of interest.

UW-Eau Claire must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any NSF action involving those records, whichever is longer.

Treatment of Subcontractors, Subrecipients, and Collaborators

When UW-Eau Claire carries out a NASA-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict of interest management and reporting on the agreement between the parties. 

See NASA definitions.

For the purposes of section 3.3, the following definitions apply:

The term “conflict of interest,” or “COI,” means a situation in which an investigator, or the investigator’s spouse or dependent children, has a significant financial interest that could directly and significantly affect the design, conduct, or reporting of NASA-funded research.

The term “significant financial interest” means anything of monetary value, including, but not limited to, salary and any payment for services not otherwise identified as salary (e.g., stock, stock options, private equity, or other ownership interest), venture or other capital financing, and intellectual property rights (e.g., patents, copyrights, and royalties from such rights). The term does not include the following:

Salaries, royalties, or other remuneration paid by the proposing institution to the investigator if the investigator is currently employed or otherwise appointed by the institution;

Any ownership interests in the proposing institution if the institution is a commercial or for-profit organization;

Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles;

Income from seminars, lectures, or teaching engagements sponsored by a public or nonprofit entity;

Income from service on advisory committees or review panels for a public or nonprofit entity;

An equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: (1) does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value and (2) does not represent more than a 5 percent ownership interest in any single entity; or

Salaries, royalties, or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the prior twelve-month period.

The term “institution’ means any domestic or foreign, public, or private, entity or organization that is applying for, or that receives, a NASA research grant or cooperative agreement.

The term “investigator” means the principal investigator, project director, and any other person, regardless of title or position, identified on the proposed project who is responsible for the design, conduct, or reporting of research funded or proposed for funding by NASA.

The U.S. Department of Justice (DOJ) awards federal funds and requires the recipients of those funds to use them in the best interest of the award program. The decisions related to the awarded funds must be free of undisclosed personal and organizational conflicts of interest. All faculty and academic staff at the University of Wisconsin-Eau Claire who participate in DOJ funded projects must fully disclose potential financial conflicts of interest and successfully complete financial conflict of interest training. See DOJ Guide Sheet. 

A. Disclosure

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to DOJ-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a plan to manage, reduce or eliminate conflicts of interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of DOJ-funded research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to: public disclosure of significant financial interests; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in the portion of the DOJ-funded research that would be affected by significant financial interests; divestiture of significant financial interests; or severance of relationships that create conflicts.

If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, such as discipline, loss of privilege to serve as an investigator on DOJ-funded research projects, and dismissal. UW-Eau Claire must keep DOJ appropriately informed if the institution finds that it is unable to satisfactorily manage a conflict of interest. Grantee notifications of conflict of interest that cannot be managed, reduced, or eliminated and awardee notifications of situations where research will proceed without the imposition of conditions or restrictions when a conflict of interest exists, must be communicated by the Executive Director for Research to DOJ.

UW-Eau Claire must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until the resolution of any DOJ action involving those records, whichever is longer.

B. Training

The investigator is responsible for successfully completing financial conflict of interest training on the federal regulation, on disclosure responsibilities, and on this UW-Eau Claire policy prior to engaging in DOJ-funded research and at least every four years thereafter. Investigators who come to UW-Eau Claire from other institutions must undergo UW-Eau Claire’s training prior to the expenditure of funds on a DOJ-funded research project. Should UW-Eau Claire find that an investigator is not in compliance with the policy or a financial conflict of interest management plan, retraining will be necessary. In the event UW-Eau Claire revises its financial conflict of interest policy and procedures in any manner that affects the requirements of investigators, retraining will be necessary.

Instructions for completing HSP Training via CITI:

Visit the CITI training website: https://about.citiprogram.org/en/homepage/
Create an account using your UWEC email address
Click "ADD a Course" in the "My Learner Tools for University of Wisconsin-Eau Claire"
Choose the appropriate course-Conflicts of Interest (COI)

Complete all modules required for your course. Successful completion requires a composite score of 80% on the quizzes. Quizzes may be repeated in order to achieve this score. A completion report will be generated when all modules are complete and a composite score of 80% has been achieved.

C. Treatment of Subcontractors, Subrecipients, and Collaborators

When UW-Eau Claire carries out a DOJ-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict of interest management and reporting in the agreement between the parties.

See DOJ Guide Sheet. 

The Department of Energy (DOE) requires the University of Wisconsin-Eau Claire to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced, or eliminated prior to the expenditure of the award funds. If an institution conducts agency-funded research through subawardees, contractors, or collaborators, the institution must take reasonable steps to ensure that the collaborating entity has its own policies in place that meet the requirements of this policy or that investigators working for such entities follow the policies of the primary institution.

These regulations promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under DOE grants or cooperative agreements will be free from bias resulting from investigator financial conflicts of interest or organizational conflicts of interest.

The Department of Energy (DOE) interim Conflict of Interest Policy and Financial Assistance Letter can be found at https://www.energy.gov/management/financial-assistance-letter-no-fal-2022-02. The applicant is subject to the requirements of the interim COI Policy and within each application for financial assistance, the applicant must certify that it is, or will be by the time of receiving any financial assistance award, compliant with all requirements in the interim COI Policy. The applicant must flow down the requirements of the interim COI Policy to any subrecipient non-Federal entities.

A.  Disclosure
According to the Department of Energy, a potential financial conflict of interest exists when an investigator has significant financial interests 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 or her immediate family (i.e., spouse and dependent children). As a result, all faculty and academic staff who plan to participate in, or are participating in, DOE-funded research must submit a Financial Conflicts of Interest Disclosure Form no later than at the time of application, within 30 days of discovering or acquiring a new significant financial interest, and at least annually during the period of award.

Examples of significant financial interests that must be disclosed include the following:

• When the value of any remuneration received from an entity in the twelve months preceding the disclosure and the value of any equity interest (e.g., stocks, stock options, or ownership interests) in the entity as of the date of disclosure, when aggregated, exceeds $5,000.
• When any equity interest in a non-publicly traded entity is held.
• Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
• Any reimbursed or sponsored travel (i.e., paid by an outside entity directly to a provider on behalf of the investigator) that is related to institutional responsibilities.

Significant financial interests do not include the following types of financial interests:

• Salary, royalties, or other remuneration paid by UW-Eau Claire to the investigator if the investigator is currently employed or otherwise appointed by UW-Eau Claire, including intellectual property rights assigned to UW-Eau Claire and agreements to share in royalties related to such rights.
• Income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles.
• Income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
• Income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to DOE-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a management plan, including appropriate compliance monitoring.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, including discipline, loss of privilege to serve as an investigator on DOE-funded research projects, and dismissal. Instances of noncompliance trigger obligations for UW-Eau Claire to conduct a retrospective review of the research conducted during the period of noncompliance to ensure that it was not biased in its design, conduct, or reporting. If bias is found, the sponsor must be notified, and a mitigation report submitted. Financial conflict of interest reports must be submitted annually thereafter.

Information concerning financial conflicts of interest held by investigators will be made accessible consistent with federal regulations. Records relating to all investigator disclosures of financial interests and UW-Eau Claire’s review of, or response to, such disclosures (whether or not a disclosure resulted in a financial conflict of interest determination), and all actions under UW-Eau Claire’s policy or retrospective review, if applicable, will be maintained for at least three years from the date the final expenditures report is submitted.

B. Training
The investigator is responsible for successfully completing financial conflict of interest training on the federal regulation, on disclosure responsibilities, and on this UW-Eau Claire policy prior to engaging in DOE funded research and at least every four years thereafter. Investigators who come to UW-Eau Claire from other institutions must undergo UW-Eau Claire’s training prior to the expenditure of funds on a PHS-funded research project. Should UW-Eau Claire find that an investigator is not in compliance with the policy or a financial conflict of interest management plan, retraining will be necessary. In the event UW-Eau Claire revises its financial conflict of interest policy and procedures in any manner that affects the requirements of investigators, retraining will be necessary.

Instructions for completing HSP Training via CITI:

Visit the CITI training website: https://about.citiprogram.org/en/homepage/
Create an account using your UWEC email address
Click "ADD a Course" in the "My Learner Tools for University of Wisconsin-Eau Claire"
Choose the appropriate course-Conflicts of Interest (COI)

Complete all modules required for your course. Successful completion requires a composite score of 80% on the quizzes. Quizzes may be repeated in order to achieve this score. A completion report will be generated when all modules are complete and a composite score of 80% has been achieved.

C. Treatment of Subcontractors, Subrecipients, and Collaborators
When UW-Eau Claire conducts a DOE-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict of interest management and reporting on the agreement between the parties.

As used in this Policy can be found in the Department of Energy’s Financial Assistance Letter.

The Department of Education (DOEd) requires the University of Wisconsin-Eau Claire to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced, or eliminated prior to the expenditure of the award funds. If an institution carries out agency-funded research through subawardees, contractors, or collaborators, the institution must take reasonable steps to ensure that the collaborating entity has its own policies in place that meet the requirements of this policy or that investigators working for such entities follow the policies of the primary institution.

DOEd requires that each investigator disclose to a responsible representative of the institution all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by the DOEd or in entities whose financial interests would reasonably appear to be affected by such activities. DOEd requires UW-Eau Claire to ensure that investigators have provided all required financial disclosures at the time the proposal is submitted to DOEd. Disclosures must be updated during the period of the award, either on an annual basis or as new reportable significant financial interests are obtained.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to DOEd-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a plan to manage, reduce or eliminate conflicts of interest. A conflict of interest exists when the reviewer(s) reasonably determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting of DOEd-funded research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to: public disclosure of significant financial interests; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in the portion of the DOEd-funded research that would be affected by significant financial interests; divestiture of significant financial interests; or severance of relationships that create conflicts.

If the reviewer(s) determines that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the reviewer(s) may allow the research to go forward without imposing such conditions or restrictions.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, such as discipline, loss of privilege to serve as an investigator on DOEd-funded research projects, and dismissal.

UW-Eau Claire must maintain records of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate.

The Environmental Protection Agency (EPA) requires the University of Wisconsin-Eau Claire to maintain an appropriate written and enforced policy on conflict of interest and that all conflicts of interest for each award be managed, reduced, or eliminated prior to the expenditure of the award funds. All faculty and academic staff at the University of Wisconsin-Eau Claire who participate in EPA funded projects must fully disclose potential financial conflicts of interest at the time of application. If an institution carries out agency-funded research through subawardees, contractors, or collaborators, the institution must take reasonable steps to ensure that the collaborating entity has its own policies in place that meet the requirements of this policy or that investigators working for such entities follow the policies of the primary institution. Disclosures must be updated during the period of the award, either on an annual basis or within 10 days of new reportable financial interests are obtained.

Financial Conflicts of Interest Disclosure Forms will be reviewed first by the investigator’s department Chair or equivalent, then by the appropriate Dean or equivalent, and finally by the Executive Director for Research. When reviewing the forms, should a potential or actual conflict be identified, the Executive Director for Research may convene an ad-hoc committee to explore the situation further. The committee will make a recommendation about whether the significant financial interest is related to the investigator’s institutional responsibilities, whether it relates to EPA-funded research, and whether it is a financial conflict of interest. If the committee concludes that a financial conflict of interest exists, they will also make recommendations for development and implementation of a management plan, including appropriate compliance monitoring.

Deliberate misrepresentation of information provided on Financial Conflicts of Interest Disclosure Forms or failure to comply with the terms of this policy may result in sanctions, including discipline, loss of privilege to serve as an investigator on EPA-funded research projects, and dismissal. Instances of noncompliance trigger obligations for UW-Eau Claire to conduct a retrospective review of the research conducted during the period of noncompliance to ensure that it was not biased in its design, conduct, or reporting. If bias is found, the sponsor must be notified, and a mitigation report submitted. Financial conflict of interest reports must be submitted annually thereafter.

Information concerning financial conflicts of interest held by investigators will be made accessible consistent with federal regulations. Records relating to all investigator disclosures of financial interests and UW-Eau Claire’s review of, or response to, such disclosures (whether or not a disclosure resulted in a financial conflict of interest determination), and all actions under UW-Eau Claire’s policy or retrospective review, if applicable, will be maintained for at least three years from the date the final expenditures report is submitted.

Treatment of Subcontractors, Subrecipients, and Collaborators

When UW-Eau Claire carries out an EPA-funded grant or cooperative agreement through subcontractors, subrecipients or collaborators, UW-Eau Claire must take reasonable steps to ensure that the subrecipient investigator is in compliance with federal regulations. UW-Eau Claire fulfills this requirement by setting forth the obligations of each party with respect to conflict-of-interest management and reporting on the agreement between the parties. 

EPA's Financial Assistance Conflict of Interest Policy

All Principal investigators, co-investigator, and participants including, undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel at the University of Wisconsin-Eau Claire who are supported by funding, in full or in part, from the National Science Foundation (NSF) or from the  U.S. Department of Agriculture, National Institute of Food and Agriculture (USDA NIFA) for research or education activities must participate in and successfully complete training in Responsible and Ethical Conduct of Research (RECR) during the grant period.  Researchers supported by other funding sources, such as internal or external grants, may also be required by their faculty mentor or funding agency to engage in RECR training. The purpose of this policy is to comply with the America Creating Opportunities to Meaningfully Promote Excellence in Teaching, Education, and Science (COMPETES) Act (42 U.S.C.1862o-1), Section 7009. Training researchers in RECR is consistent with the mission of the UW System, UW-Eau Claire, the goals of the Center of Excellence for Faculty and Undergraduate Student Research Collaboration, and the commitment of faculty to collaborative interaction, promoting excellence in teaching and learning, and disciplinary expectations.

This policy is currently active for all students, graduate students, and postdoctoral researchers paid under NSF grants. As of July 1, 2024, the policy will apply to faculty and other senior personnel on NSF grants.

The plan to train undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel in RECR involves identification, notification, training, and verification. The Director of the Office of Research and Sponsored Programs will be the primary individual responsible for compliance with this plan.

Identification and Notification:
The Office of Research and Sponsored Programs will notify faculty Principal Investigators (PIs) of their obligation to ensure their own training as well as that of all other researchers (i.e., undergraduate students, graduate students, postdoctoral researchers, and other senior personnel) on their research project. In turn, faculty PIs will contact their undergraduate students, graduate students, postdoctoral researchers, and other senior personnel on their project to inform them about RECR training and set timelines for successful completion.

Training and Verification:

The University of Wisconsin-Eau Claire’s RCR training emphasizes instructional areas suggested by the U.S. Department of Health and Human Services, Office of Research Integrity and guidelines from the National Institutes of Health.

Training is satisfied through the completion of the appropriate CITI Program Responsible Conduct of Research (RCR) course. Faculty and other senior personnel are required to complete   Faculty (RCR) (ID: 193902), which includes required mentor training; students are required to complete Students - Required (RCR) (ID: 193894). The amount of time to complete the interactive online tutorials is estimated to be between one and three hours; they do not need to be completed in one sitting. Researchers are required to successfully complete the training once during the grant period, either prior to or in the early weeks of the research work. If a researcher completed RECR training at another institution, they must repeat training using the appropriate CITI Program course under UW-Eau Claire.

CITI Program has a built-in system for verification. During registration on CITI Program, researchers indicate affiliation with UW-Eau Claire. Upon completion of the course, a record is kept in the online system and can be verified by the Office of Research and Sponsored Programs. Researchers can also access certificates of completion on the CITI Program website.

The Office of Research and Sponsored Programs will notify researchers (and the faculty PI mentor) of instances of noncompliance with the RECR plan and recommend a course of action and timeline for fulfilling requirements. This RCR plan is part of the University of Wisconsin-Eau Claire’s ongoing commitment to passing along high ethical standards to the next generation of scholars.  

Persistent failure to comply may result in a restriction of access to resources in the Office of Research and Sponsored Programs, including access to internal grants and external grant support.

Additional resources on mentoring best practices are available on ORSP’s website under Mentor Resources and on the Online Ethics Center website, recommended by NSF.

I. Policy

UW-Eau Claire will adhere to the following agency requirements whenever award terms and conditions include notification requirements regarding sexual harassment, other forms of harassment, or sexual assault:  

• National Science Foundation (NSF) or National Aeronautics and Space Administration (NASA) requirements whenever the term and condition regarding sexual harassment, other forms of harassment, or sexual assault is included in an NSF- or NASA-funded award or subaward agreement.
• National Institutes of Health (NIH) prior approval policy for changes in the status of PIs and senior/key personnel, as described in Notice NOT-OD-18-172 and per requirements.
• Simons Foundation regarding notification requirements in their Grant Code of Conduct. 

UW-Eau Claire’s process to address the National Science Foundation (NSF), National Aeronautics and Space Administration (NASA), National Institutes of Health (NIH), or Simons Foundation requirements will include the following steps.

• Twice per year, the Office of Research and Sponsored Programs (ORSP) will email a list of active NSF, NASA, NIH, and Simons Foundation awards to the Affirmative Action and Provost offices.
• Affirmative Action and Provost offices will review the list and either confirm no reporting required or provide details, per agency requirements and definitions of sexual harassment, other forms of harassment, or sexual assault.
• At any time, whether during the bi-annual check or other time, if an administrative leave or action is imposed, the Affirmative Action and/or Provost office will provide necessary information to ORSP.
• ORSP is responsible for submitting any notification to the granting agency, which is due within 10 business days (NSF, NASA, and Simons Foundation) or 30 days (NIH) of the date of the administrative leave/action or finding/determination.
• ORSP will work with NSF, NASA, NIH, or Simons Foundation, and other appropriate offices as needed, with the primary goals of ensuring the safety and security of other award personnel and the continued progress of the funded project. Actions that may be necessary may include, but are not limited to:
  • Replacement of the PI or Co-I
  • Review of expenditures on the award
  • When necessary, transfer of unallowable charges off the award 

Administrative leave or action: Any temporary/interim suspension or permanent removal of the PI or co-I, or any administrative action imposed on the PI or co-I by the awardee/recipient under organizational policies or codes of conduct, statutes, regulations, or executive orders, relating to activities, including but not limited to the following: teaching, advising, mentoring, research, management/administrative duties, or presence on campus. 

Finding/determination: The final disposition of a matter involving sexual harassment or other form of harassment under organizational policies and processes, to include the exhaustion of permissible appeals exercised by the PI or co-I, or a conviction of a sexual offense in a criminal court of law. 

UW-Eau Claire Affirmative Action Policies 

UW System related policies: Sexual Violence and Sexual Harassment and Discrimination, Harassment, and Retaliation 

It is NSF policy (see PAPPG Chapter XI.A.1.g.) to foster safe and harassment-free environments wherever science is conducted. At the time of application, for any NSF proposal that proposes to conduct research off-campus or off-site, UW-Eau Claire must complete a certification that the organization has a plan in place for that proposal that describes how the following types of behavior will be addressed:

1. Abuse of any person, including, but not limited to, harassment, stalking, bullying, or hazing of any kind, whether the behavior is carried out verbally, physically, electronically, or in written form; or
2. Conduct that is unwelcome, offensive, indecent, obscene, or disorderly.

University Responsibility: This procedure reflects UW-Eau Claire’s plan for safe and inclusive working environments for off-campus or off-site research.

Principal Investigator (PI) Responsibility: The PI is responsible for modifying this plan with any project-specific details (as needed) and understanding, communicating, and implementing this plan with all project participants. The PI must share a copy of this plan that contains any project-specific modifications with ORSP. Unless otherwise noted in a specific NSF program solicitation, the plan should not be submitted to NSF for review.

UW-Eau Claire Plan for Safe and Inclusive Working Environments for Off-Campus or Off-Site Research:

Nurturing an inclusive off-campus or off-site working environment

UW-Eau Claire has established the following policies to nurture safe and inclusive working environments:

• Affirmative Action Policies Affirmative Action | Knowledge Base | UW-Eau Claire (uwec.edu)
• Guide to Student Safety Policies: Guide to Safety Policies | UW-Eau Claire (uwec.edu)
• Blugold Student Conduct Code Policies: Blugold Student Conduct Code | UW-Eau Claire (uwec.edu)
• Student/Staff Incident Report eForm: Student/Staff Incident Report | UW-Eau Claire (uwec.edu)

UW-Eau Claire has a Responsible Conduct of Research (RCR) Policy applicable to all who are supported by funding, in full or in part, from the National Science Foundation for research or education activities to participate in and successfully complete training in RCR. This includes individualized instruction related to RCR provided by faculty mentors.

Requiring communications within project team and to the organization

The PI will share this plan, including any project-specific details, with all project participants who conduct research off-campus or off-site. The plan should be shared prior to departure for any off-campus or off-site research.

Providing a process to submit, receive, and resolving incident reports

UW-Eau Claire has established the following policies/procedures:

• Affirmative Action Policies Affirmative Action | Knowledge Base | UW-Eau Claire (uwec.edu)
• Student/Staff Incident Report eForm: Student/Staff Incident Report | UW-Eau Claire (uwec.edu)

Research off-campus or off site is defined as data/information/samples being collected off-campus or off-site, such as fieldwork and research activities on vessels and aircraft.