What you need to know about changes to the Outside Activities Report form and Conflict of Interest
Using the OAR to steer your way through the compliance waters on campus just got easier.
In fact, over the summer, upgrades were made to the UW–Madison Outside Activities Report (OAR) form. The changes not only make it easier to ensure that you are in compliance with campus policy, but also will save you time and effort when completing the form, thereby reducing administrative burden.
All faculty, regardless of appointment, all academic staff with 50% or greater appointment, and all individuals listed as participants on human subject protocols or as key personnel on federal grants are required to fill out an annual OAR and update it within 30 days of a change. OARs must be filed annually by April 30th.
If you filed an OAR in 2018, your most recent OAR as of August 6th, 2018 was migrated into the new system, along with your management plans and management plan signatures.
Upgrades to the new system include a refreshed interface now supported by all modern web browsers, a streamlined OAR form with fewer questions and more branching logic, a database of all previously reported entities, the ability to see both active and inactive relationships, and the ability to see all active grants and human subject protocols. And, starting next year, instead of signing management plans annually, you will need to only sign once for the duration of your relationship with an entity.
In addition to the OAR, the UW–Madison Conflict of Interest Policy requires all investigators engaged in federally funded and/or human subjects research to receive training in financial conflict of interest. This conflict of interest training must be completed every four years.
Over the summer, a new Conflict of Interest training course was made available in Canvas. The COI Office will be sending emails to investigators who need to take this COI training course. Please contact the COI Office if you have any questions about this. You also can learn more by reading the Conflict of Interest FAQs.
Why does this matter? For one thing, it is the right thing to do.
UW–Madison prides itself as being a model for transparency and maintaining integrity in its research enterprise. The importance of outside activities at UW–Madison is captured in the Wisconsin Idea, where knowledge gained from academic enterprise is shared to benefit society. Faculty and staff are encouraged to participate in outside activities, share expertise, and transfer intellectual property to the private sector.
Your participation in outside activities may generate conflicts between the needs of the institution and the outside entity. UW–Madison understands that these conflicts are common, frequently unavoidable, and can be appropriately managed.
The UW also has a responsibility to its funding partners.
Recently, Francis Collins, Director of the National Institutes of Health, issued a statement for the NIH extramural research community about NIH’s concern that foreign entities have mounted programs to influence NIH research. Collins noted, “the robustness of the biomedical research enterprise is under constant threat by risks to the security of intellectual property and the integrity of peer review.”
Collins cited three areas of concern:
- Failure by some researchers at NIH-funded institutions to disclose substantial contributions of resources from other organizations, including foreign governments, which threatens to distort decisions about the appropriate use of NIH funds
- Diversion of intellectual property in grant applications or produced by NIH-supported biomedical research to other entities, including other countries; and
- In some instances, sharing of confidential information by peer reviewers with others, including in some instances with foreign entities, or otherwise attempting to influence funding decisions.
In response, NIH is working with NIH-funded academic and other institution to identify robust methods to improve accurate reporting of all sources of research support, financial interests, and affiliations; mitigate the risk to intellectual property security while continuing NIH’s long tradition of collaborations, including with foreign scientists and institutions; explore additional steps to protect the integrity of peer review. While new federal requirements in this area have not yet been defined, the flexibility of our new OAR system will make any new reporting requirements simple to implement and help investigators ensure they are in compliance.
These actions serve as an important reminder of our research responsibilities and the importance of following policies and procedures for disclosing outside activities and relationships.
For UW-Madison, following those requirements is easier now and we are grateful for the work of several Office of the Vice Chancellor for Research staff, including Conflict of Interest Specialists Sam Leinweber and Stephanie LeRoy, Senior IT consultants Chip Quade and Patrick Lally, Associate Vice Chancellor for Research Policy and Integrity Brian Fox and Assistant Vice Chancellor for Information Technology and Chief Information Officer Nick Tincher.
– Office of the Vice Chancellor for Research and Graduate Education