Policies, Procedures and Guidelines

Who is Required to Submit a Financial Disclosure

a. All faculty with an academic appointment of instructor or higher on tenure or non-tenure tracks.

  • Includes: Tenure-track faculty, Non-tenure-track faculty (Research, Clinical, Practice, Visiting appointments).
  • May include: Adjunct or Emeritus if they have effort and are involved in research.
  • Does not typically include: Lecturers or Courtesy appointments

b. Individuals, who by definition have independent responsibility for the design, conduct, or reporting of research at WUSTL, which includes:

  • Principal Investigator/Project Director
  • Co-investigator
  • Key personnel
  • Mentors and fellows on individual fellowship grants
  • Mentors identified on institutional training grants

c. Any other individual, who regardless of title or position, has or may have independent responsibility for the design, conduct, or reporting of the research. The Principal Investigator (PI)/Project Director (PD) is responsible for making the determination of who meets this definition, which may include:

  • Collaborators/consultants
  • Research/Staff Scientists
  • Trainees/Students
  • Individuals who do not have an appointment at WUSTL, but have the above role/designation related to research being conducted at WUSTL

d. Subrecipients 
As part of WUSTL’s assurance of compliance with federal regulations related to financial conflicts of interest, WUSTL is required to incorporate as part of a written agreement with the subrecipient, terms that establish whether the financial conflict of interest policy of WUSTL or that of the subrecipient will apply. This standard is applicable to PHS and NSF sponsored research or any other sponsoring agency that has COI requirements for subrecipients. If a subrecipient defers to WUSTL’s policies and process, the individuals involved in the design, conduct, or reporting of the research are considered covered individuals.