Policies, Procedures and Guidelines

Financial Disclosure Procedure

Original Effective Date 09/30/2003
Last Revised Date 08/16/2018

Financial Disclosure Statement via Research Management System (RMS):

For all covered individuals who have any type of WU appointment, the disclosure statement can be accessed at http://coi.wustl.edu. System instructions are available here.

If the individual is transferring to WU, 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-WU form is required:

For covered individuals who do not have an appointment at WU. 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-WU Financial Disclosure Statement

    • The individual will complete a Non-WU Financial Disclosure Statement via the Research Management System (RMS), which can be accessed at http://rms.wustl.edu using your WUSTL Key ID and password. System instructions are available here.
    • For First Time Users: Prior to being able to access the system, a Non-WU Intake Form needs to be completed and submitted to coi@wustl.edu or via fax 314-362-8712.
    • Once received, the Office of Research Integrity & Ethics will provide the individual with his/her user ID (WUSTL Key) and temporary password via email.
    • 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.

– 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 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.