Policies, Procedures and Guidelines

Financial Disclosure Procedure

Washington University Annual Financial Disclosure Statement is required:

For all covered individuals who have any type of WUSTL appointment, the disclosure statement can be accessed through RMS at https://rms.wustl.edu. System instructions are available on the Financial Disclosure System page.

If the individual is transferring to Washington University, an appointment can be entered into the Human Resources Management System by the applicable payroll department, which will allow access to the system within 24 hours

COI Certification or Non-WashU form is required:

For covered individuals who do not have an appointment at Washington University. 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 Financial Disclosure Statement

    • The individual will complete a Non-WUSTL FInancial Disclosure Statement and submit it 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.
      • At the time the Non-WashU Financial Disclosure Statement is processed, the Research Ethics and Compliance Office will provide, via email, the individual with his/her user name and password along with the URL to access the education module.
      • It is the responsibility of the individual to complete the education module if the project receives funding.

– or –

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.

Travel Disclosure

For those individuals required to disclose travel, they will be emailed each month and prompted to disclose any material travel using a disclosure form​ that will be included in the email. Then the individuals may email, fax, or send via campus mail to the CIRC for review.