As a recipient of funds that support research, UWM must monitor compliance with various federal and state laws as well as sponsor policies and regulations. An overview of the various compliance offices, functions, and roles across campus appear below.
Animal Care Program
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
Biological Safety Program
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.
Biological Safety Program Website
Effort Reporting: 2 CFR 200.430
Effort reporting is the method of certifying to federal granting agencies that the effort required as a condition of the award has actually been completed. Federal regulation requires individuals who expend committed effort on a sponsored project or are paid from a sponsored project to certify their effort. Effort certification assures award sponsors that (1) investigators have met their commitments and (2) sufficient effort was devoted to justify salary charges to sponsored awards. See 2 CFR 200.430.
What do I need to do?
If you receive compensation from a sponsored award or you have committed effort on a sponsored project:
- Register in the CITI system; select University of Wisconsin-Milwaukee from the dropdown menu.
- Complete the Effort Reporting training.
- Certify your effort semi-annually using the ECRT effort certification system.
The Office of Sponsored Programs will ensure all individuals subject to the UWM Effort Policy have certified their outstanding effort statements and completed effort training prior to setting up new sponsored awards.
The UWM Guidelines for Effort Reporting is a comprehensive desk reference that provides detailed instructions for certifying effort.
ECRT was upgraded to the latest version in December 2015. This upgrade will improve our effort reporting process. Certifiers will “click” fewer times to get to certification, and certification will take fewer “clicks” to complete. For assistance certifying in the upgraded ECRT system, here are two helpful references:
- How to Certify Effort for Faculty and Staff.
- Certifiers Quick-Start Guide (abbreviated version of “How to Certify Effort for Faculty and Staff”).
The University of Wisconsin-Milwaukee must foster and protect an environment of openness and academic freedom to sustain and strengthen its research and higher education mission. Avenues of inquiry should be unlimited, participation in research and the academic community unrestricted, and dissemination of knowledge unfettered.As policy, 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 UWM’s community from participation in research. In particular, foreign faculty, students, or scholars should not be singled out for restriction in access to UWM’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.
Allowability of Export Controlled Projects
The Vice Provost for Research may grant exceptions to this policy to the extent such exceptions are consistent with applicable laws and UW-System and Board of Regents’ policies. Exceptions will be rare and may be granted only where the research is critically important to UWM’s mission and serves a demonstrable greater good or where the impact on open research is limited. For example, exceptions may include, but are not limited to, accepting export controlled information if it is tangential to the intellectually significant portions of the research and extending the length of time for publication review. If these conditions are not met, UWM will decline or discontinue the research or, if an acceptable off-campus affiliate is available to conduct such research, consider whether a collaboration arrangement between UWM or its researchers and the affiliate is appropriate.
Fundamental Research Exemption
Both of the policy statements described above support 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 such, most UWM research will be exempt from export controls. However, where export controls are applicable to our research activities, UWM will require full compliance with the law.
Laws Governing Export Controls
The export of certain technologies, software and hardware is regulated and controlled by Federal law for reasons of national security, foreign policy, prevention of the spread of weapons of mass destruction and for competitive trade reasons. UWM and all its employees are required to comply with the laws and implementing regulations issued by the Department of State, through its International Traffic in Arms Regulations (ITAR), the Department of Commerce, through its Export Administration Regulations (EAR) and the Department of the Treasury through its Office of Foreign Asset Controls (OFAC). Export control regulations apply regardless of the source of funding, both external and internal.
UWM research involving specified technologies controlled under the EAR and/or ITAR, or transactions and exchanges with designated countries, individuals and entities may require UWM to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in controlled research, collaborating with a foreign company and/or sharing research—verbally or in writing—with persons who are not United States citizens or permanent residents (U.S. Persons). The consequences of violating these regulations can be quite severe, ranging from loss of research contracts and exporting privileges to monetary penalties and jail time for the individual violating these regulations.
Export control regulations affect not only research conducted on campus, but also travel and shipping items outside the U.S. Simply traveling to certain sanctioned countries could require a license from the OFAC. OFAC sanctions prohibit transactions and exchanges of goods and services in certain countries and with designated persons and entities. Multiple lists of denied individuals and parties are maintained and enforced by federal agencies including the Departments of State, Commerce, and Treasury. Shipping items outside the U.S. as well as taking controlled items on a flight, even if shipping or traveling in the conduct of research, could require a license from these agencies.
UWM is committed to export control compliance. Office of Sponsored Programs (OSP) oversees many aspects of export control compliance for UWM, contact Tom Marcussen with questions.
Financial Conflict of Interest
The UWM COI Program protects 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 the UWM. In response to federal regulations, state laws, and UW System policy, individuals at UWM must disclose their outside financial interests annually and must update their disclosure throughout the year as their outside interests change.For PIs, co-investigators, and key personnel on PHS-funded awards, the UWM PHS FCOI Program promotes objectivity in research by ensuring research is free from bias resulting from investigator financial conflicts of interest.What do I need to do?
Complete the Outside Activities Disclosure Report. This form is required for all UWM PIs and co-investigators on federal grants, UWM faculty, academic staff and limited appointees with appointments of 50% or greater, and all individuals with active management plans from the UWM Conflict of Interest Committee.If you are PI, co-Investigator, or key person on a Public-Health Service (PHS)-funded award, complete the Significant Financial Interest Disclosure Form and FCOI Training.
Human Subjects Protection
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).
- To determine whether you need an IRB review for your project, complete the Determination of UWM IRB Submission Form.
- Investigators whose research involves human subjects must complete required Human Subjects Training.
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.
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.
University Safety and Assurances
Responsible Conduct of Research
What is it?
The National Science Foundation (NSF) and the National Institutes of Health (NIH) require that all undergraduate students, graduate students, and post-doctoral researchers who receive financial support for research through NSF or NIH must receive training and oversight in the responsible and ethical conduct of research (RCR). UWM uses CITI training for its basic RCR training; in addition, UWM can work with researchers to provide supplemental training for RCR topics on request; contact Kari Whittenberger-Keith, RCR Co-Director (firstname.lastname@example.org), for more information.What do I need to do?
You can access CITI RCR training here. Contact Kari Whittenberger-Keith if you have questions.
Kari Whittenberger-Keith, RCR Co-Director.