Conflicts of InterestHuman Subjects Research

Guidance on Contingent Workers and Non-appointees for Non-WashU Researchers and Pre/Post Employment Research Roles

Last Revised: June 11, 2024

Overview
Contingent Workers
Pre-Employment (Incoming Faculty/Researchers) Process
Post-Employment (Departing Faculty/Researchers) Process
FAQs
Contacts
Guest ID Usage and Process

Overview

Contingent Workers is a broad category covering non-employees in Workday. Workday@WashU has established guidance and procedures on Contingent Workers for the University as a whole. This document is an expansion of that guidance specifically for research purposes. The WashU Research Community encompasses a diverse spread of individuals within and outside the University. A significant number of individuals not employed or holding an appointment at WashU may be involved (directly or indirectly) in research or other WashU activities. This includes domestic and international research collaborators, visiting researchers and faculty, and students (across all educational levels). Additionally, these individuals may engage remotely while others have a physical presence on campus and in laboratories. Lastly, there are also groups that contract with WashU to utilize space or resources at WashU for their own pursuits and interests that are distinct and separate from WashU activities.

For individuals, who are not compensated by the University and need to obtain training and security access, there two options are available and primarily depends on the anticipated needs and role with WashU:

  1. Contingent Workers: Non-WashU person with direct involvement in WashU research, under an agreement to utilize WashU space/equipment for non-WashU purposes or requiring WUSTL key access to certain WashU systems related to research. 
  2. Guest WUSTL Key: Option for obtaining a temporary WUSTL Key to complete a one-time training through Learn@Work and for which having a Contingent Worker profile in Workday is not necessary. Examples of this include BJC employees needing WashU human subjects or Good Clinical Practice training or Research Monitors who need to complete HIPAA training.
  3. Academic Affiliates: Non-employees that hold no position and are not in a supervisory organization. Typically include Emeritus and Volunteer Faculty. Academic Affiliate appointments are NOT acceptable for research purposes as Research Compliance programs do not have oversight authority over affiliates nor an ability to monitor for compliance.

It is critically important to correctly identify the most appropriate option and for Contingent Workers, the subtype.

Contingent Worker appointments related to research should NOT be used for the sole purpose of retaining access to email or WUSTL Box.

Contingent Workers (CW)

For non-WashU persons having an ongoing substantive interaction (more than 2 days) with WashU based on role, systems access, or training needs, they must be entered in Workday as a Contingent Worker.

  • Contingent Worker is a category within Workday and covers various types of non-employees across WashU.
    • 14 subtypes based on role and relationship to the University, most of which are not used for research purposes.
  • Only WashU personnel with the appropriate security access in Workday (typically HR Partners) can create/edit Contingent Worker profiles within Workday.
    • Department Admins and faculty should work closely with their respective HR Partners or other authorized individuals to ensure Contingent Workers are set up appropriately within Workday.
  • Important to correctly identify subtype (subtypes are not all equal)
    • The subtype helps convey key aspects of the overall relationship between the person and WashU.
    • Collaborating Investigator and Facility Access Only will use their home institution email address (not a WUSTL email account) for work email. The non-WUSTL email must be entered into Workday in the ‘Work Email Address’ field at the time the profile is established/updated to ensure appropriate systems access. The manually entered Work Email will not be overwritten by overnight processes.
    • Contingent Workers must be assigned to a Sup Org and Cost Center within Workday. With few exceptions these should match the department and faculty member overseeing the related research.
  • Positions and Business titles should either match the Contingent Worker type or accurately describe the individual’s role (e.g. Visiting Professor).  Do not use another Contingent Worker type as the business title or position (e.g. Using ‘Collaborating Investigator’ as the business title for a Security Access Only appointment).

Contingent Worker Subtypes

Commonly Used for Research Population

(with few exceptions, non-WashU persons involved in research with WashU will be in one of these subtypes)
Infrequently Used for Research Population

(funding source for person may require these subtypes to be used)
NOT to be Used for Research Population

(subtype must be changed to an acceptable research subtype)
Collaborating InvestigatorResidentExternal Time Approver
Visiting Researcher*Non-Paid Fellows (clinical fellows)Student Clerkship
Academic Services Access (formerly Visiting Faculty)Independent ContractorSecurity Access Only
Facility Access OnlyAgency Temp/ConsultantLeased Affiliates
Non-Paid Postdoc (Externally Funded)Non-Appointee*(see description below for limited use with students/minors)
Academic Affiliates (not a CW subtype)
*must complete non-appointee process

Detailed Descriptions of Contingent Worker Subtypes as They Relate for Research Purposes

Full list and detailed descriptions of all contingent workers are located here.

CW TypeDescriptionKey DifferentiationsExamples
Collaborating InvestigatorNon-WashU person, NOT on site, collaborating with WashU researchers on specific projects and having a direct role in WashU research, or is a sub recipient on a WashU research project.

Non-WashU person will be on-site for training purposes only and requiring access off-site after training.

Departing WashU faculty or staff – as part of the PI Departure Process needing limited systems access for more than 90 days past the termination date for projects that will not be addressed through transfer, subaward, or other institutional agreement. (e.g. mentoring or projects in a NCE and will not be transitioned to a subaward).
*If individual is on-site use Visiting Researcher type for non-Faculty or Academic Services Access type for Faculty. 
 
Non-WashU email account must be entered for the Primary Work Email Address in Workday along with the work phone number for proper system access and contact information. Access to box folders can still be granted by sending the sharing invite to their non-WashU email address.

Cannot be used for engagement in animal or human studies protocols.
An offsite non-WashU person, identified as a key person on a funding application, who needs WashU to certify their compliance with WashU’s research compliance policies (e.g. someone opting to follow WashU’s COI policy as their home institution has no COI policy or their policy is not PHS compliant, and the research is NIH funded).

Former WashU faculty member serving as mentor on a K-award at WashU.

Sub-award recipients opting to follow WashU’s research compliance policies as part of the contractual agreement with WashU.
Visiting ResearcherResearcher or Pre-doc/Postdoc/Grad Student from another institution coming to WashU to gain specific experience/knowledge in specific research or laboratory processes or techniques or having direct involvement in WashU research activities.

May have an appointment or affiliation at another academic institution or entity.

Non-appointee packet is required to be completed.
If primarily off-site and engagement is limited to a specific project, use Collaborating Investigator.

If an individual is classified as a visiting researcher, but is able to engage in activities remotely, still use this worker type. 

Do not use if primary purpose is training and will not have direct involvement in WashU research.

For engagement in human or animal studies, department must inform and obtain approval from the IRB or IACUC as appropriate.
Staff scientist from another University visiting WashU for one month over the summer to learn new techniques.

Non-WashU Students on Training Visas (J-1 Visa holders).

Non-WashU Pre-docs, Post docs, and Graduate Students.
Academic Services Access (formerly Visiting Faculty)Available for individuals as defined in more detail in the Academic Services Access Guidelines Policy, however for research purposes this type is primarily used for Visiting Faculty and Incoming (pre-hire) faculty. On rare occasion this type may be used for departing faculty with appropriate approvals and justification.
 
Visiting faculty from another institution at WashU to gain experience/knowledge on a particular research, clinical processes, or techniques. May also have direct involvement in WashU educational and research activities while on site.
 
Non-appointee packet is required to be completed for former WashU faculty approved to retain short-term access in completing the PI Departure Process:
https://hr.wustl.edu/non-appointee-visitor-observer/

Paid Visiting Faculty must be entered in an employee role.
Visiting faculty must hold a faculty position at another academic institution. 

Typically, if the individual is off-site and engaged in research, use Collaborating 
Investigator. 

For engagement in human or animal studies, department must inform and obtain approval from the IRB or IACUC as appropriate.
Non-WashU Faculty on sabbatical from another University on-sight at WashU to collaborate with a WashU Investigator (Visiting Faculty).

Pending new WashU faculty member expected to arrive in the coming months but needing to apply for funding opportunities due before their start date. (Incoming faculty).

Former WashU Faculty member completing the analysis and manuscript for a grant in No-Cost-Extension set to end in 60 days, after which no further access will be needed.
Facility Access OnlyRequired to be used for individuals affiliated with an entity where they will be using WashU services, space, or equipment and needs on-site access to facilities or online software /databases, etc.  The usage of the service, equipment, or space is for non-WashU purposes.
 
Physical areas and equipment to be made available must be established via a formal (e.g. facilities use) agreement between WashU and external groups/companies. Training may be required and/or provided by WashU to ensure safety and compliance requirements are met.
If the individual will be on-site for training purposes only and then transitioning offsite, use Collaborating 
Investigator.  
 
Non-WashU email account must be entered as the Primary Work Email Address in Workday along with the work phone number for proper system access and contact information. Access to box folders can still be granted by sending the sharing invite to their non-WashU email address.
External entity/ company employees onsite to use WashU specialized equipment, facilities, lab space, resources as prescribed in a signed and executed Facilities Use Agreement.

Employees associated with faculty start-up company coming on-sight to learn sample process techniques to transition this task to the company as part of an executed licensing agreement. 
 
Affiliated partners using contracted WashU services (e.g. UHSP/formerly STLCOP).
Non-Appointees (limited use by EH&S for research purposes)Non-Appointees are generally not used for research purposes, however a limited subset of non-WashU students, and minors are entered as Non-Appointees and covered by EH&S for research purposes.

Non-WashU students (undergraduate or minors) must be enrolled in an academic program outside of WashU for the purpose of completing requirements to receive academic credit as part of a clinical education course, or class.

For all other Non-Appointees: cannot have direct involvement with work involving research activities (data entry, collecting, analyzing, or reporting) or clinical practice.

Non-Appointee Student, Visitor/Observer Process
*For non- WashU students with direct involvement in WashU research activities; use Visiting Researcher

*For non-WashU students; verify Facility Access Only should not be used as the type before using this one.

Required entry in Workday if non-appointee will be on-campus for more than three days.

NOTE: This Contingent Worker type is NOT acceptable for COI, IACUC, or IRB coverage.
Visitor one-day request to observe a surgery, or a five-day request to shadow a Physician.

High School and Non-WashU Undergraduate Students attending research courses over the summer.

Goldfarb NP Student, UMSL Students of Social Work, SLU Students of Psychology doing rotations at WashU as part for their degree program.

Pre-employment (Incoming Faculty) Process

Frequently, incoming faculty will have a need to have an active Workday profile weeks or even months before their official start date. An incoming faculty may be transferring existing funding to WashU, need to submit for grants with due dates prior to their hire date, submitting protocols for IACUC review. To meet these needs and allow for a seamless transition, the new faculty will need to have a Contingent Worker profile set up:

  1. An Academic Services Access type Contingent Worker profile should be used for incoming faculty needing early access or whose profile must be available to other systems (e.g. RMS, L@W, LAMPS) prior to their official hire date.
  2. The Contingent Worker profile should be set up before any employee role or position is added. Basic steps:
    • Follow the Academic Services Access Guidelines for getting the appropriate approvals and signatures.
    • Create the Contingent Worker profile in Workday, with the Type as Academic Services Access
    • Set the position as Contingent Worker-Academic Services Access and update the Business Title to align with the anticipated faculty title upon hire (e.g. Associate Professor).
    • Set the Contract Start Date as the current date to ensure the incoming faculty’s profile is available to integrated systems.
    • On or just before the hire date, use the Convert Contingent Worker process to hire the faculty member and discontinue the Academic Services Access CW role.

Post-employment (Departing Faculty/Researcher) Process

Faculty and researchers departing from the University may have research, or may be involved in other’s research, that is not ending upon their departure. As they are no longer employees of the University, the research engagement must transition to a collaborative relationship, no different to how the University engages with our other Non-WashU researchers. Follow the steps below to ensure a smooth transition.

  1. Use the PI Departure Process to account for every project or protocol (human and animal).  This process will aid in establishing a plan for which projects will 1) transfer to the new institution, 2) need a subcontract or agreement created for any continued engagement, 3) need updating to remove the individual or closed.
  2. Involve the appropriate resources and offices well in advance of the actual departure date to help establish and implement the departure plan:
    • SPA and OSRS for grants that may be transferred to the new institution
    • JROC for contracts that may transferred or subcontracted to the new institution
    • HRPO Office for assisting in transferring any human studies protocols or removal from protocols
    • IACUC Office for animal research activities or any open IACUC protocols
    • IBC and Radiation Safety for open protocols
  3. In rare instances, research will not be transferred, and a subcontract or other agreement is not a viable option, (e.g. unpaid mentorship on a K award, or a grant is in NCE and expected to end in a few months). If there is sufficient justification for retaining a level of involvement in the research AND not execute an agreement between WashU and former employee’s new institution, it may be feasible to transition the departing faculty to a Contingent Worker role. The proposed plan should be documented via the PI departure process and approved by the OVCR along with other applicable approvals. The type of role will depend in large part on the duration and the level of access required:
    • Short term (<90 days generally) can be transitioned to an Academic Services Access role. The Academic Services Access Guidelines must be followed.
    • Longer term (>90 days) can be transitioned to a Collaborating Investigator role. Note: access to box folders will need to be re-established once the transition is complete. The Work Email Account in Workday will also need to be updated to reflect the faculty member’s email address from their new employer.
    • Contingent Worker roles are NOT to be used for general or continued access to data or systems post termination.
  4. Post Termination
    • All access to WashU systems and data is to be termed absent approval for a specific need attributable to a research project as identified during the PI Departure Process.
    • Access to institutional systems such as EPIC, should always be terminated when departing employees end their WashU employment. Access to these systems as a Contingent Worker must be requested from the appropriate office.
    • Access to myIRB is automatically terminated when WashU employment ends. IRB oversight for the faculty/researcher also ends when WashU employment ends. Obtaining contingent worker status is not a mechanism to continue IRB oversight of the faculty/researcher. Contact HRPO for questions about IRB oversight.
    • Further Access to WashU data or materials should be accomplished through appropriate agreements such as subcontracts, MTAs, unfunded collaboration agreements, and data use/sharing agreements. JROC should be consulted to determine the appropriate agreement.
    • e. Contingent Workers are not permitted to be PI on WashU grants. Consult with SPA for questions.

Contingent Worker FAQs

To assist in ascertaining the appropriate subtype:

Why do I need to enter a Work Email Address when I set up new Collaborating Investigators or Facility Access Only Contingent Workers when we are instructed to NOT do that for all the other Contingent Workers or any new employees?

Collaborating Investigators and Facility Access Only subtypes are the types that do not get a WashU email account. Therefore, it is necessary to manually enter both the Home Email Address and Work Email Address when setting up the account in Workday, which should reflect the email address they commonly use for communications. This ensures any systems that pull Workday data for contact information will use that email address for any system generated emails or communications.

  • Specifically for Facility Access Only workers: If the email addresses are not entered correctly, these contingent workers will not be able to access LAMPS or submit IACUC protocols. Collaborating Investigators are not covered by IACUC and cannot submit protocols.

What is the difference between Visiting Researcher and Collaborating Investigator?

Collaborating investigators are off-campus and involved in specific projects (usually only one) with a very specific role. Visiting Researchers are typically involved in a variety of projects, are onsite receiving training in addition to being engaged in research. Some exceptions may be made for remote status, although those are usually temporary. Visiting Researchers must go through the non-appointee process.

A staff scientist is leaving WashU but will continue to have a small role in wrapping up a research project, what steps are necessary?

Use the PI Departure Process (it works equally well for staff scientists) to identify all active projects and establish a plan on which, if any, warrant continued involvement by the staff scientist. Work with JROC to establish the appropriate agreements with the scientist’s new institution (e.g. collaboration agreements, data use agreements, or subcontracts). If there is adequate justification for not establishing an agreement between the institutions, the staff scientist may receive authorization to have an active Workday profile as a Contingent Worker, Collaborating Investigator subtype or Academic Services Access. See the above section on Departing Faculty/Researchers.

Our department already has a process for handling departing faculty with research, can we just continue to follow that rather than The Post-employment (Departing Faculty/Researcher) process?

Departments may have a developed or documented process, or come up with ‘creative’ methods to handle departures that seem easier or faster, but also result in problematic situations that can take significant effort and resources to correct. An existing process must account for and include all of the components outlined in the post-employment process described above, otherwise the above process should be used instead. This allows for a uniform and standardized approach that reduces the likelihood of transitional issues resulting after the departure date.

I have a Visiting Researcher CW who would like to continue to use their non-WashU email address, is this possible?

No, only Collaborating Investigators and Facility Access Only subtypes are able to use a non-WashU email address as their Work Email Address. All others have the Work Email Address field automatically populated with a WashU email address.

If a non-WashU person seems to meet more than one CW definition, which one should we use? (e.g. someone is an Independent Consultant for non-research related project but now is also going to serve as a mentor on a grant)

  • Whenever possible, the research role should be given priority over other roles, however if there is a legal need (such as funding source) to list a person as another type (e.g. Agency Temp), then that should be given priority.
  • As for the research roles, priority is as follows: Visiting Researcher > Facility Access Only > Collaborating Investigator. Work with your research administration contact if you are uncertain which subtype is most appropriate.

My non-WashU researcher is currently a ‘Security Access Only’ subtype, why am I being asked to change them to another subtype?

The different subtypes help to establish how this person relates to WashU and whether we are willing to take responsibility for this person’s engagement in research at WashU. Having individuals in a vague subtype can result in an inaccurate understanding of what this person’s role at WashU entails and in some instances, result in the incorrect access to systems or resources being provided.

I am adding a Facility Access Only/Collaborating Investigator who already has a @wustl.edu email address as an alum, can they use that email address?

No, they will need to use the email address for their current employer or institution.

My visitor is only going to be here for less than three days, do they need to be a Contingent Worker profile created in Workday?

It is important for the University to be aware when visitors are on campus, as there are safety considerations for laboratories along with confidentiality of data and PHI. HR guidance states that individuals normally identified as Contingent Workers but requesting access for less than 3 days may use a WUSTL Guest key in lieu of entry in Workday. Non-appointees and Visiting Researchers will still be required to complete the appropriate paperwork. Contingent Workers are not permitted access to Epic or PHI without approval from the HIPAA Office, as applicable.

I have a research collaborator that will be coming onsite infrequently and may need more access than what a Guest or Collaborating Investigator subtype provides, but Academic Services Access or Visiting Researcher also does not seem appropriate since their visits will be infrequent and short. What type of Contingent Worker should we use?

a. For unique situations or circumstances, we recommend contacting your Department Administrator or the appropriate compliance office (e.g. contact the IACUC Office if the purpose of the person coming on site relates to animal studies). Otherwise contact the COI Office at COI@wustl.edu.

Additional FAQs will be added based on feedback, and as new information becomes available.

Contacts

For questions regarding Non-WashU Researchers and Contingent Workers contact:

  1. Your Department Administrator or Business Manager
  2. Conflicts of Interest Program COI@wustl.edu or 314-747-4181
  3. Institutional Biological and Chemical Safety Committee at ehsibc@wustl.edu
  4. Environmental Health & Safety at ehs@wustl.edu
  5. Institutional Animal Care and Use Committee at iacuc@wustl.edu
  6. Office of Research Integrity & Ethics at ORIE@wustl.edu
  7. HR Dept. – Non-Appointees at nonappointees@wustl.edu

Access the full Contingent Worker and Guest ID Guidance for Workday.

Guest WUSTL Key

The Guest WUSTL key process may be used in place of adding someone as a Contingent Worker in Workday for anyone that needs a WUSTL Key just to complete a one-time training through Learn@Work and for whom the Non-Appointee Student, Visitor/Observer process is not applicable. Non-Appointee Students, Visitors/Observers must be entered into Workday as a Contingent Worker and a Guest WUSTL Key should not be used.


Examples of this include BJC employees needing WashU human subjects or Good Clinical Practice training or Research Monitors who need to complete HIPAA training.

  • A guest is not paid by the University, nor are they a full-time or part-time student
  • Accounts are temporary (1-12 months only) and are automatically inactivated
  • Requires a department sponsor (current faculty or staff representing the guest) and Department Approver (based on sponsor’s department) to approve the request
  • Training records remain in L@W after guest account is inactivated for reporting purposes
  • Guest profiles are NOT linked to Workday (don’t use for pre-hires)
4 step process for Guest WUSTL Key requests. 1) Guest submits a completed request form. 2) Sponsor will approve or deny. 3) Departmental approver will approve or deny. 4) Guest will receive approved or denied notification email.

Instructions and guidance on the Guest WUSTL Key process are located on WashU IT’s website.