Policies, Procedures and Guidelines

Request Information Available to the Public

Washington University (WUSTL) shall provide to any requestor written information about Financial Conflicts of Interest, which were determined to be a Financial Conflict of Interest related to Public Health Services (PHS)-funded research on or after August 24, 2012, in accordance with 42 CFR Part 50 and 45 CFR Part 90 and this procedure. Information concerning Financial Conflicts of Interests of an individual subject to these requirements shall remain available upon written request for at least three years from the date the information was most recently updated.

Procedures

1. Requests must be in writing and received either through the US mail or via email.

  • Mailing address: Research Ethics and Compliance Office, Campus Box 1054, One Brookings Drive, St. Louis MO, 63130
  • Email address: coi@wustl.edu

2. The request must include the following:

  • PHS project number (e.g., 1R01CA12345-06)
  • Name of the senior/key personnel about whom information is being requested.
  • First and last name of the requestor and a return email address or physical street address, P.O. Boxes are not acceptable.

3. WUSTL’s response will be postmarked or dated (if replying by electronic means) within 5 business days of the receipt of the request.

4. Information concerning an individual will be provided if the following criteria are met:

  • The individual is identified as senior/key personnel by WUSTL in the grant application, progress report, or any other required report submitted to PHS;
  • The personal financial interest was disclosed and is still held by the individual; and
  • WUSTL determines the personal financial interest is related to the PHS-funded project and is a Financial Conflict of Interest.

5.  If all the criteria set forth in Section 4 above are met, the following information will be provided to the requestor:

    • Project Number;
    • Name of the individual;
    • Individual’s title and role with respect to the research project;
    • The name of the entity in which the financial interest is held;
    • Nature of the financial interest (e.g. equity, consulting fee, travel reimbursement, honorarium);
    • Approximate value of the financial interest (in ranges), or a statement that the interest is one whose valued cannot be readily determined through reference to public prices or other reasonable measure of fair market value; and
    • A statement that the information is accurate as of the date of the response and that it is subject to updates in accordance with applicable law.

6. If the request does not meet the requirements of Section 4 above, WUSTL will so inform the requestor within the timeframe indicated in Section 3.