Research Integrity and Compliance

Institutional Research Integrity

Integrity in scholarship, teaching, and research is a fundamental principle at UWM. In our research endeavors, we share a guiding value to engage in ethical behavior based on integrity, accountability, and responsibility. Our administration, faculty, staff, and students all share the responsibility for preserving the integrity of research conducted at UWM.

Responsible Conduct of Research (RCR) Training

Responsible conduct of research (RCR) is defined as “the practice of scientific investigation with integrity.” It involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.

Education in the responsible and ethical conduct of research is essential in the preparation of future scientists and engineers. UWM encourages all faculty, staff, and students to complete RCR training. However, some federal sponsors require all project personnel financially supported by a grant to receive training in the responsible conduct and ethical practice of research. Failure to complete this requirement may cause UWM to be non-compliant with federal rules and thus subject to fines or debarment from future federal grants.

The purpose of RCR training is to:
  • Develop, foster, and maintain a culture of integrity in research
  • Discourage and prevent unethical conduct
  • Empower researchers to hold themselves and others accountable to high ethical standards
  • Increase knowledge of, and sensitivity to, ethical issues surrounding the conduct of research
  • Increase knowledge about the regulations, policies, statutes, and guidelines that govern the responsible conduct of research
RCR training subject matter includes:
  • Research ethics and integrity
  • Disclosing and managing conflicts of interest and/or commitment
  • Sound research design and methodology
  • Reproducibility
  • Conscientious data management
  • Appropriate authorship
  • Appropriate mentorship
  • Appropriate use of grant funds
RCR Training at UWM

UWM uses the online CITI training system to satisfy federal responsible conduct for research training requirements. For more information, see the instructions for accessing the CITI RCR training.

Guidance

For more information about RCR training requirements for specific federal sponsors, see UWM’s guidance on Federal RCR Training Requirements.

UWM RCR Training Contact
Jeff Nytes (jpnytes@uwm.edu) Research Compliance Manager

Research Misconduct

UWM fosters a research environment that discourages misconduct in all research and deals forthrightly with allegations of research misconduct. The responsibility for preserving the integrity of research conducted at UWM is shared by administration, faculty, staff, and students.The UWM Policy on Research Misconduct defines research misconduct as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. The policy describes the steps in the determination of whether allegations of misconduct require further inquiry and investigation and includes the process for inquiry and investigation. The Research Misconduct Policy applies to anyone who, at the time of the alleged misconduct, was employed by, was an agent of, or was affiliated by contract or agreement with UWM. This includes faculty, staff, employees in training, students, contractors, volunteers, and guests.

For matters regarding research misconduct, contact Kristian O’Connor, the designated Research Integrity Officer for UWM and the Acting Vice Provost for Research and Interim Dean of Graduate School, at 414-229-2866 or krisocon@uwm.edu.

Fiscal Integrity

Fiscal integrity is a shared responsibility across UWM. Units, including the Division of Finance and Administrative Affairs; the Office of Research; Schools, Colleges, Divisions; and Principal Investigators work together to ensure that UWM is meeting its federal and state compliance obligations.

UWM Office of Research

Financial Award Management
Financial award management requirements ensure that UWM is a responsible steward of our sponsor’s resources.

Contact:
Office of Sponsored Programs
-Director: Kate Mollen
-Assistant Director, Post-Award Administration: Carla Durand

UWM Division of Finance and Administrative Affairs

Extramural Support Administration Policy
Outlines parameters related to extramural support, which includes gifts, grants, sponsored contracts, and cooperative agreements.

Contact:
Business & Financial Services
-Financial Manager: David Rice
-Controller: Anthony Helmke

Fiscal Misconduct
Fiscal misconduct is defined as “a deliberate act or failure to act that is contrary to established laws, regulations or policies and which results or was intended to result in either loss or other damage to the State or the UW System or improper personal gain.”

Contact:
Finance and Administrative Affairs
If you suspect someone is engaging in fiscal misconduct:
-Notify your supervisor, who is obligated to inform UWM’s Vice Chancellor for Finance and Administrative Affairs.
Or
-Complete the UWM fraud reporting form. A representative from the Office of the Vice Chancellor for Finance and Administrative Affairs will contact you.

Sponsored Project Purchasing and Procurement
Guidance on procurement practices in accordance with State laws and UW System and UWM policies, procedures, guidelines, and best practices.

Contact:
Business & Financial Services
-Procurement Director: Scrivener, Tom

 

Institutional Research Compliance

All UWM researchers are subject to sponsor, state, and federal regulations. Research compliance functions including effort reporting, conflicts of interest, and export controls are overseen by UWM’s Research Compliance Manager in the Office of Research.

Payroll Certification (Effort)

UW-Milwaukee recognizes the importance of providing good stewardship in managing extramural funds. The university’s stewardship responsibilities include complying with federal requirements to certify faculty and staff compensation on federally sponsored projects.

To meet the requirements of 200.430 – Compensation for Personal Services, payroll must be certified for all individuals who expend committed effort on federal sponsored projects or are paid from a federal sponsored project. Payroll certification provides documentation that award salary charges are appropriate for the work performed.

UW-Milwaukee’s procedures for proposing, charging, and certification of compensation on sponsored projects can be found in the guidance document titled “Guidelines for Effort Commitments and Payroll Certification Associated with Sponsored Projects.

Project-Based Payroll Certification

UWM uses Project-Based Payroll Certification to meet the requirements of 200.430 Compensation for Personal Services. Project-Based Payroll Certification occurs twice a year using ECC (the Employee Compensation Compliance tool).

For project-based payroll certification, the Principal Investigator, or their approved designee, is responsible for certifying project payroll.

Staff who serve as PI or approved designee on federal sponsored projects must complete a one-time training program on the principles of effort commitments and payroll certification. The Basics of Effort, Commitments and Payroll Certification training is managed through CITI. Please go to the CITI website and log in with your UWM credentials to access the training.

Policy

UWM Sponsored Programs Compensation Compliance Policy

Guidance Document

Guidelines for Effort Commitments and Payroll Certification
ECC Quick-Start Guide for CCCs
ECC Quick-Start Guide for PI Certifiers

Intro Videos

ECC and Payroll Confirmation Online Training

CITI Training

The Basics of Effort, Commitments and Payroll Certification

Forms

Certification Delegation Request Form

Contact:
Jeff Nytes
UWM Research Compliance Manager

Export Control

Introduction

In the interest of national security, the U.S. government has enacted numerous laws and regulations which operate to restrict the use of, and access to controlled information, goods, and technology by persons and entities outside the U.S. and certain foreign persons inside the U.S. These laws and regulations are collectively referred to as “export control regulations.” As an Institution of Higher Education advancing fundamental research, most UWM research is excluded from export control regulations.

Fundamental Research

Openness in research and free dissemination of research results are core values at UWM, as institutionalized in our Openness in Research Policy. The policy supports the fact that research conducted by the faculty, staff, and students of UWM is Fundamental Research as that term is defined in National Security Decision Directive 189.

As an Institution of Higher Education advancing fundamental research, most UWM research is excluded from export control regulations. However, where export controls are applicable to UWM’s research activities, UWM is committed to fully complying with all applicable export control regulations.

Allowability of Export Controlled Projects

Openness in Research
In order to sustain and strengthen its research and higher education mission, UWM policy promotes openness in research and academic freedom. UWM will not undertake research with restrictions on openness or academic freedom on its campus. Examples of unacceptable restrictions include classification, required external approval of research results before publication, or exclusion of members of the University’s community from participation in research. In particular, foreign faculty, students, or scholars should not be singled out for restriction in access to the University’s educational and research activities. Most research can be conducted in accord with this policy and the ideals of freedom of inquiry and open exchange of knowledge.
As a result, Controlled/Restricted research may only be conducted at UWM with prior approval from the Vice Provost for Research.

Controlled/Restricted Research
UWM recognizes that, in some instances, the best interests of society will mitigate against broad participation in research and the open exchange of information. As a result, the Vice Provost for Research (VPR) may grant project-based exceptions to the Openness in Research policy to the extent such exceptions are consistent with applicable laws and UW System policies. An exception to UWM’s Openness in Research policy is required prior to the conduct of controlled research, the VPR opens UWM to the potential to carry out controlled research projects. In choosing to accept or decline projects that infringe upon open research, the VPR will weigh the potential of a project for generating and disseminating new knowledge supporting the mission of the University against the project’s potential for adversely affecting the climate for research conducted in a free and open environment.

Policy and Guidelines

Export Controls in Research Policy
Openness in Research Policy
Export Controls in Research Program Announcement
Guidelines for Export Controls in Research

Training Resources

UWM Guidelines for Export Controls in Research
UWM Export Controls Overview Training
UWM Export Controls Overview Training Slides
UW-Madison Export Control Training page

Bureau of Industry and Standards (BIS) trainings:
Export Controls Quick Start video
Export Control Classification video
Deemed Exports Training video

US National Archives Controlled Unclassified Information (CUI) trainings:
CUI Training page
CUI Training video

Topic Resources:
Export Control Overview
Export Control Glossary
Regulations
License Requirements
Deemed Export
Controlled Research – Foreign Staff/International Students
International Travel
International Shipping

Research Security Training

The U.S. National Science Foundation, in partnership with the National Institutes of Health, the Department of Energy and the Department of Defense, has provided online research security training for the broad research community.

Research Security Training provides recipients of federal research funding with information on risks and threats to the global research ecosystem — and the knowledge and tools necessary to protect against these risks.

The four-part series may be viewed at: NSF Research Security Training

Forms

Technology Control Plan Template
Export Control Screening Form
Export Control Assessment Form

Questions

Contact the Export Controls in Research Program, or the Research Compliance Manager Jeff Nytes with questions.

Research Conflict of Interest

UWM has an obligation to manage conflicts of interest as part of ensuring the integrity of research at the university. Conflict of Interest refers to a situation in which financial interests or other personal considerations may affect or have the appearance of affecting an Investigator’s professional judgement or actions in the design, conduct, or reporting of Research and Other Sponsored Programs or that might interfere with the Investigator’s duties or responsibilities to UWM. It includes actual conflicts/activities or potential conflicts/activities, real or perceived.Investigators engaging in, or proposing to engage in, Research or Other Sponsored Programs are required to report Conflicts of Interest that reasonably appear to be related to the Investigator’s institutional responsibilities. These interests are to be reported annually on the Investigator’s Outside Activities Reports. In addition, Investigators must update their Outside Activities Reports within 30 days of acquiring or discovering a new Conflict of Interest. Timely disclosures protect employees and the institution by identifying and preventing situations in which there is a conflict between an employee’s personal interests and that employee’s public responsibilities to UWM.

Policy and Guidelines

UWM COI in Research Policy
UWM COI Guidance

Outside Activities Reporting (OAR)

Research Conflict of Interest Committee (RCOIC)

Management Plans

UWM Management Plan Template

Public Health Services (PHS) Research

For PIs, co-investigators, and key personnel on PHS-funded awards (i.e., NIH, CDC, FDA), additional steps are required that focus specifically on Financial Conflict of Interest (FCOI).

UWM PHS COI Policy
FCOI Training
Significant Financial Interest Disclosure (SFID)

Questions

The Office of Research is given the responsibility and authority to conduct an ongoing conflict of interest program for research and other sponsored programs at UWM. If you have questions about research-related conflicts, Management Plans, or FCOI/SFID, contact Jeff Nytes, Research Compliance Manager, or the UWM Research Conflict of Interest Committee.

For assistance with the annual outside activities disclosure process, please consult the OAR Toolkit and if you have questions, contact OAR Support.

 

Research Laboratory Compliance

UWM has various programs to promote safety, compliance, and environmental health in order to facilitate education and research for the faculty, staff, and students. The following laboratory research compliance functions are overseen by UWM’s Office of University Safety & Assurance.

Animal Care Program

What is it?

Provides for the care, health, and well-being of animals used for research and education at UWM.

What do I need to do?

If you intend to work with vertebrate animals, you will need to complete Animal Care Training and submit the required Animal Care Training Forms.

Contact:

Biological Safety Program

What is it?

Protects the health of the UWM community by identifying and managing biohazardous materials and recombinant DNA used in campus activities.

What do I need to do?

You must complete specific training programs and registration forms when working with certain biological materials. Click on each link above to identify the biological safety training program(s) and form(s) required for your research.

Contact:

Human Subjects Protection

What is it?

The HRPP is the home of the Institutional Review Board (IRB) for the protection of human subjects. The IRB holds autonomous decision making when reviewing human subject research studies at UWM. The mission of the IRB is to ensure the adequacy of the research plan, to minimize risks, and to maximize the potential for benefit for human subjects who participate in research.

What do I need to do?

Sponsored projects that involve human subjects are required to be approved by the UWM Institution Review Board (IRB).

Contact:

irbinfo@uwm.edu

Laboratory Safety

What is it?

Promotes safety, compliance, and environmental health in UWM laboratories, shops, and studios.

What do I need to do?

Principal investigators, lab supervisors, or individual departments must prepare a Chemical Hygiene Plan and standard operating procedures for their laboratories.

Contact:

For training and plan preparation support, Jennifer Herriges, Chemical Hygiene Officer, University Safety and Assurances.

Radiation Safety

What is it?

The UWM Radiation Safety Program manages the safe use of radioactive material on campus through training, laboratory audits, laboratory surveys, radionuclide control and inventory, personal dosimetry and waste disposal.

What do I need to do?

Principal investigators are responsible for ensuring their personnel are properly trained in radiation safety techniques as described in the UWM Radiation Safety Manual.Use of byproduct radioactive materials, accelerator produced radionuclides, naturally occurring radionuclides, and machine produced radiation requires authorization. To obtain authorization, you must complete and submit the required forms to the Radiation Safety Program.

Contact:

University Safety and Assurances