Financial Conflict of Interest Procedures

Page Updated: November 21, 2025

UW-Madison’s procedures to address the Public Health Service (PHS) Financial Conflict of Interest Policy, which became effective August 24, 2012, are described below. The Department of Energy (Energy) released an Interim FCOI policy on December 20, 2021, which will be addressed through a similar process as PHS awards.

Prior to proposal submission, the University must obtain information from each proposed subrecipient about whether the subrecipient (1) has their own PHS- or DOE-compliant financial conflict of interest policy, as applicable per the prime source of funding, or (2) does not have a policy and will agree to be subject to UW-Madison's policy on financial conflict of interest.

At award setup time RSP will request all conflict of interest obligations (OAR Disclosure, FCOI Training, Management Plan Reporting) for all key personnel listed on the COI Status tab. Guidance is available at the UW COI Office's website.

Please ensure that Award key personnel are identified as FCOI investigators in the Personnel section of the RAMP Award SmartForm prior to COI review. The FCOI Investigators will appear on the COI Status tab. You can notify RSP that the key personnel are ready for COI review by:

• Completing the Other Ancillary Review; or
• Submitting comments only to the Ancillary Review or Sending an Email from the Award Workspace indicating that the personnel on the COI Status tab is set

After confirmation of key personnel on the COI Status tab, RSP will load this RAMP award to the FCOI App and send an Ancillary Review to the COI Office to begin the COI review process, if necessary.

The COI Office Ancillary Review should remain open until all conflict of interest obligations are completed.

See RSP Notice 2013-1 for more information on subrecipients and the PHS FCOI policy.

FCOI Policy Process Map