Review of Academic Staff under Federal Guidelines
Federal regulations require institutions to review reports from investigators for potential conflicts of interest. The federal definition of investigator is broad and includes more than individuals named as principal investigator (PI) or co-investigators (Co-Is) on federal grants. The federal definition may include UW-Madison academic staff who are involved in federally-funded or human subjects research.
The Public Health Service (PHS) definition is: “Investigator means the principal investigator and any other person who is responsible for the design, conduct, or reporting of research funded by PHS, or proposed for such funding. For purposes of the requirements of this subpart relating to financial interests, "Investigator" includes the Investigator's spouse and dependent children” (42 CRF 50.603).
Similarly, the National Science Foundation (NSF) definition is: “The term "investigator" means the principal investigator, co-principal investigators, 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” (NSF, Grant Policy Manual 510).
Thresholds for Review
The COI Committee reviews academic staff members when:
- an individual reports outside activities that meet federal criteria for significant financial interests (42 CRF 50.603; NSF, Grant Policy Manual 510), AND
- the individual’s position at the UW-Madison would allow them to affect the design, conduct, or reporting of federally-funded research.
Identification of Individuals for Review
The COI Committee identifies academic staff members as possibly subject to review when:
- An individual is listed as a PI or Co-I on federally fund research in UW-Madison’s Extramural Support Information System (ESIS).
- An individual reports that he or she is a principal investigator or otherwise responsible for the design, conduct, or reporting of federally funded research or sponsored projects in his or her annual outside activities report.
- An individual has a significant financial interest in an entity, AND other individuals, who also have a significant financial interest in that entity, are being reviewed by the COI Committee.
- A Dean’s Office requests review of an individual.
Review of Academic Staff Who Conduct Human Subjects Research
Academic staff engaged in research with human subjects are reviewed under the UW-Madison Financial Conflicts of Interest in Human Subjects Research: Policies and Procedures.