Conflicts of Interest

Financial Disclosure Procedure

Original Effective Date 09/30/2003
Last 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 payroll department.

COI Certification or Non-WU form is required:

For covered individuals who do not have an appointment at WashU. Fulfillment of the disclosure requirement may occur in one of the following ways, unless a disclosure is required as part of the subrecipient agreement:

  1. Non-WashU External Professional Activities disclosure
    • The individual will complete a Non-WashU External Professional Activities disclosure via the Research Management System (RMS), which can be accessed at https://rms.wustl.edu using their assigned WUSTL Key ID and password. Systems and Procedures (314-935-5707) can provide assistance with forgotten WUSTL Keys and resetting passwords. System instructions are available here.
    • If a financial conflict is identified, the PI/PD of the project and the individual will work with the CIRC to develop an acceptable management plan; and,
    • The individual will be required to complete the University’s Financial Conflict of Interest education module if the project is funded. It is the responsibility of the individual to complete the education module if the project receives funding.
  2. Letter of Compliance
    • The individual may obtain a letter from his or her home institution, certifying compliance with federal requirements regarding financial conflicts of interest. A letter template is provided for your reference. Individuals submitting a letter of compliance will also require a Contingent Worker profile in Workday for record retention purposes.

For First-Time Users

  • In order to access the system, a Contingent Worker (CW) profile in Workday must be created by the Department of the WashU PI following the CW guidance available.
  • Once created, the Contingent Worker name and ID# is submitted to coi@wustl.edu or via fax to 314-362-8712.
  • If a financial conflict is identified, the PI/PD of the project and the individual will work with the CIRC to develop an acceptable management plan; and:
  • The individual will be required to complete the University’s Financial Conflict of Interest education module if the project is funded. It is the responsibility of the individual to complete the education module if the project receives funding.

Travel Disclosure

For those individuals required to disclose travel, they will be emailed each month and prompted to disclose any material travel via the Research Management System (RMS), which can be accessed at http://coi.wustl.edu. See the Travel Disclosure Procedures and Guidance for additional information. System instructions for disclosing travel are are available here.