External guidelines  

• Protection of Human Subjects
• Protection of Animals
• Scientific Misconduct Policy and Procedures
  
• Fringe Benefit
• Indirect Cost Rates
• Investigator Financial Disclosure Policy
• Glossary of Definitions
  
  

Protection of Human Subjects

The UW-Eau Claire policies and procedures for the protection of human subjects have been established in accordance with U.S. Department of Health and Human Services regulations (45 CFR Part 46, "Protection of Human Subjects," as amended) as well as state and University regulations to protect the rights and welfare of human subjects utilized in research projects. Any research project, either funded or unfunded, originated at or supported by the University, that involves human subjects must be reviewed and approved by the Institutional Review Board for the Protection of Human Subjects. The Guide to the Preparation of proposals for Submission to the Institutional Review Board for the Protection of Human Subjects is available in the Office of Research and Sponsored Programs. 

Protection of Animals

The UW-Eau Claire Institutional Animal Care and Use Committee (IACUC) is responsible for the review and approval of any research, research training, experimentation, and biological testing and related activities involving live vertebrate animals. The contact person is Dr. David Lonzarich, Chair, IACUC, 836-3260, lonzard@uwec.edu

Scientific Misconduct Policy and Procedures

Misconduct in science is defined as fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, conducting, or reporting research. Misconduct in science is prohibited and could result in disciplinary action up to and including dismissal. UW-Eau Claire’s Policies and Procedures on Scientific Misconduct document indicates how the University will respond to allegations of research misconduct. 

Fringe Benefit

Fringe benefit rates to be used by the University of Wisconsin-Eau Claire in charging external funds for the employer's contribution to fringe benefits are set by UW System. These are found at: www.uwsa.edu/fadmin/fringes.htm. Contact the Office of Research and Sponsored Programs for assistance when developing grant proposal budgets.

Indirect Cost Rates

It is the policy of the University of Wisconsin-Eau Claire to recover the Federal Negotiated Indirect Cost Rate from all agencies that are legally bound by that agreement and from all other federal, state, and private funding sources that will reimburse the University at the negotiated rate. There are two different rates, on-campus and off-campus. Both rates are calculated using the same formula. These rates are based on the total salaries, wages, and fringe benefits being requested in the grant or contract proposal.

Investigator Financial Disclosure Policy

Filing Requirement

Consistent with applicable federal regulations (Federal Register Vol. 59:33242-33251 and 33308-33312, June 28, 1994 and Federal Register Vol. 60:35810-35823, July 11, 1995), and to assure timely processing of applications for federal funding, an investigator who is planning to participate in federally funded research or educational activities must submit a UW-Eau Claire Investigator's Financial Disclosure Form (IFDF) to their department chair or equivalent prior to University transmittal of their proposal to a federal agency. Federal regulations define "investigator" as the principal investigator, co-principal investigators, and any other person who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by a federal agency.

University Research and Creative Activity Council

The University Research and Creative Activity Council (URCAC) will review potential conflicts arising under this policy. The URCAC shall be chaired by the Assistant Vice Chancellor of the Office of Research and Sponsored Programs and will consist of faculty and/or academic staff members who are experienced researchers and federal grant-seekers, as well as appropriate administrators. The committee shall meet as necessary to carry out its responsibilities under this policy.

Review Process

Within 10 working days of receipt, the investigator's department chair or equivalent must review, sign, and forward the IFDF to the appropriate Dean or equivalent.

The Dean shall review the IFDF within 10 working days of its receipt. If the Dean determines, after reviewing the IFDF, that no conflict of interest exists, s/he shall notify the investigator, the URCAC and the Office of Research and Sponsored Programs of the determination. Upon such a determination by the Dean, the expenditure of any awarded funds may proceed.

If the Dean determines, after reviewing the IFDF, that a potential for conflict of interest exists, s/he will notify the investigator, the URCAC, and the Office of Research and Sponsored Programs of the potential conflict of interest. If an investigator with a potential conflict of interest decides to proceed with proposal to a federal agency, the investigator must also send an abstract of the proposal and an explanation of why there is no conflict, or an explanation of potential solutions to the conflict, to the URCAC. If, after review of the submitted documentation, the URCAC decides there is no conflict of interest, the URCAC will notify the investigator, the Dean, and the Office of Research and Sponsored Programs.* Upon such a determination by the URCAC, the expenditure of any awarded funds may proceed.

If the URCAC decides that a conflict of interest does exist, it will convene a meeting with the investigator and the investigator's Dean. At the meeting, any party may suggest ways to eliminate, resolve, or manage the conflict of interest.** If the URCAC, the Investigator, and the Dean agree on how to manage the conflict, the URCAC will notify the Office of Research and Sponsored Programs that the conflict of interest is manageable and that the University can expend the federal funds if awarded.

If a conflict cannot be resolved or managed by the above process, an appeal process shall be provided. If an investigator requests an appeal, the investigator's Dean shall convene and preside over a [three to five]-member appeals committee, consisting of at least one representative from the URCAC, and other qualified persons appointed by the chancellor.

If the conflict is resolved or managed through the appeal process, the Office of Research and Sponsored Programs shall be notified that the conflict of interest is manageable and the university can expend the federal funds if awarded. If the conflict is not resolved or managed through the appeal process, the university may not expend any federal funds awarded. Conflicts involving funded research and educational activities which cannot be satisfactorily managed, reduced, or eliminated through this process will be disclosed to the appropriate federal agency.

If, during the course of the proposal review or grant award, circumstances concerning an investigator's significant financial interests change, the investigator shall submit a revised IFDF to his/her department chair or equivalent, and the above steps for reviewing the revised IFDF shall be followed.

The Office of Research and Sponsored Programs will maintain records of all Investigator's Financial Disclosure Forms and of all actions taken to resolve or manage potential conflicts of interest for at least three years after the termination or completion of the award to which they relate or until resolution of any federal action involving those records, whichever is longer. _____________________________________________________________

* A "no conflict of interest" determination could arise in the following circumstances: if the investigator's income is not from a "for profit" business; or, if the investigator's income is from textbook writing.

** One way a conflict could be managed is for the URCAC to appoint a 2-3 member project oversight committee. Ideally, members of a project oversight committee would have expertise in areas related to the investigator's proposed research area. All project oversight committees would be required to file annual reports with the URCAC concerning their ongoing role in the management of the conflict. Section 50.605 of Subpart F, 42 CFR Part 50, and Federal Register Vol. 60: 35822, July 11, 1995, includes several other suggestions for managing a conflict of interest.

Glossary of Definitions

Reference: Federal Register Vol. 59:33308-33312 and 33242-33251, June 28, 1994 & Federal Register Vol. 60:35810-35823, July 11, 1995

Types of interests that are reportable:

Types of interests that are NOT reportable:

Formula to determine whether a financial interest is reportable:

1. Do you and/or your immediate family* have a financial interest from or in a for-profit business that is reasonably likely to be affected by the research or educational activities for which you have received or expect within the year to seek and receive funding? If not, then the interest is not reportable. If yes, go to Step Two.
2. Do you and/or your immediate family* together receive from such a business $10,000 or more per year, or is the ownership interest you and your family have together in such a business 5% or more, or equal to or greater than $10,000 in value, of the total ownership interest? If no, then the interest is not reportable. If yes, you must report the interests on the other side of this form (ifdf).

* IMMEDIATE FAMILY means your spouse and dependent children.