All faculty, regardless of appointment, all academic staff with 50% or greater appointment, and all individuals listed as participants on human subject protocols or on federal grants are required to fill out an annual Outside Activities Report (OAR) and update whenever new outside activities are undertaken. This includes any financial interests related to the research in accordance with University of Wisconsin policies on Conflicts of Interest and Institutional Conflict of Interest.

In the event a study team member (including the PI) has a conflict of interest management plan for a specific study, the IRB will consider this as part of its review process and, if deemed necessary to protect the rights and welfare of study participants, may require additional measures be implemented (e.g., consent monitoring) beyond those included in the management plan. For more than minimal risk studies, a conflicted individual cannot serve as key personnel without the exception to the management plan (approved by COI Committee).

We recommend reaching out to the Conflict of Interest office directly for assistance with questions regarding the OAR process, potential conflicts of interest, and conflict of interest training requirements.

See HRP 055-SOP-IRB Review of Financial Conflicts of Interest.