Uniform Guidance

All federal funding (grants, contracts, etc.) must adhere to the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, commonly referred to as the Uniform Guidance (UG). The UG establishes requirements and guidance relating to costs allowed on federal grants. The Uniform Guidance was […]

Rights and Responsibilities of Individuals Involved in Research Misconduct Proceedings

December 10, 2010 Complainant/Witness Respondent Individuals providing requested information Research Integrity Officer Members on the Committee on Research Integrity Office of Research Integrity & Ethics (ORIE) Vice Chancellor for Research Deans Department Heads Office of the Executive Vice Chancellor and General Counsel (OGC) Legal counsel/advisor for the respondent Complainant/Witness Rights Protection from retaliation for his/her […]

Financial Disclosure Procedure

Original Effective Date 09/30/2003Last Revised Date 07/20/2023 External Professional Activities disclosure via Research Management System (RMS): For all covered individuals who have any type of WashU appointment, the disclosure can be accessed at http://coi.wustl.edu. System instructions are available here. If the individual is transferring to WashU, an appointment can be entered into Workday by the applicable […]

Monitoring Procedures

Original Effective Date 1/1/2007Last Revised Date 3/20/2020 Washington University (WU) monitors compliance with FCOI management plans to verify management plan activities have been appropriately implemented in accordance with the prescribed strategies in the following circumstances or as required by the CIRC: Monitoring is conducted on an ongoing basis until the completion of the research project, […]

Request Information Available to the Public

Effective: 08/24/2012Revised:10/6/2023 Washington University (WashU) shall provide to any requestor written information about Financial Conflicts of Interest, which were determined to be a Financial Conflict of Interest related to research on or after August 24, 2012, as applicable and in accordance with federal regulations including 42 CFR 50 Subpart F, 45 CFR 94 and 2 […]

Financial Interest Disclosure Reviewing Thresholds

Conflict of Interest Review CommitteeEffective: August 24, 2012Last Revised: September 28, 2023 Reportable financial interests, defined as anything of monetary value, regardless of whether the value is readily ascertainable, must be disclosed as described in External Professional Activities to Disclose. Disclosure requirements for the Research COI policy include financial interests and activities occurring in the […]

Dispute Resolution/Appeals Procedure

Original Effective Date 08/27/2002 Last Revised Date 08/24/2012 Introduction The WUSTL Research Conflicts of Interest Policy states “Unresolved disagreements concerning the application of this policy shall ultimately be referred for final resolution to a committee established by the chancellor or representative appointed by the chancellor.” This procedure outlines the necessary steps individuals shall take to resolve […]

Determining and Managing Research FCOIs Procedures

Last Revised Date 11/9/2023 1. Introduction The Conflict of Interest Review Committee’s (CIRC) procedures will comply with all applicable federal regulations and funding agency requirements. The following describes the Conflicts of Interest Review Committee’s (CIRC) procedures and considerations for a) reviewing individuals’ personal financial interests, b) determining whether there is a material financial interest, c) evaluating […]

Timing of Disclosures

Original Effective Date 09/30/2003Last Revised Date 05/25/2022 All faculty with an academic appointment of instructor or higher and all individuals, who by definition have independent responsibility for the design, conduct, or reporting of research at WashU are required to proactively submit a disclosure: Upon request by the Office of Research Integrity & Ethics (ORIE) or […]

FCOI Education Requirements

Effective: August 24, 2012Last Revised: September 28, 2023 Introduction The WUSTL Research COI Policy states “A covered individual must complete training in regard to this policy and applicable federal regulations as established by the University and/or applicable federal regulations.” Central to Washington University’s mission of fostering excellence in research is a commitment to ensure that individuals […]