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Revised Institutional Conflict of Interest Policy

Published June 10, 2024, via Research News

A set of recommendations for updating the Institutional Conflict of Interest Policy (“ICOI Policy”), developed by an advisory committee in conjunction with the ICOI Committee (ICOIC), have been approved by the Chancellor. The overarching purpose of these changes is to align Washington University’s policy with peer institutions, and implement a risk-based approach for evaluating and managing institutional conflicts of interest (ICOI) related to research while maintaining a high level of oversight for human studies research. This is the first significant revision to the policy since its implementation in 2009.

Key policy updates:

  • Revise the definition of ‘Institutional Official’ to focus on an individual’s responsibilities vs solely by title. The new definition requires “Any roles/positions, as identified by the school deans, having final decision making authority over faculty appointments, salaries, and promotions; AND responsibilities for resource allocations necessary to support research activities”. Of note, this approach aligns with identifying school Designated Reviewers under the External Professional Activities policy.
  • Establish a risk-based policy model to a) eliminate the default position that either the research or the financial interest be eliminated to avoid ICOIs for all human studies research, unless compelling circumstances exist; and b) refine the use of compelling circumstances justification to align with research ICOI risks including assessing for potential benefit to research participants as a factor.
  • Update the review thresholds of Institutional Official’s and the University’s to move away from using the federally-mandated Individual (research) COI Policy to thresholds, including eliminating the review and management of the University’s financial interests when not related to human subject research. This aligns with the risk-based approach.

The updated policy and procedures are available on the COI website. For any questions, please contact the COI Program at 314-747-4181 or