Conflict of Interest Review Committee
Effective: August 24, 2012
Last Revised: September 28, 2023
Reportable financial interests, defined as anything of monetary value, regardless of whether the value is readily ascertainable, must be disclosed as described in External Professional Activities to Disclose. Disclosure requirements for the Research COI policy include financial interests and activities occurring in the preceding 12 months or anticipated in the next 12 months from the date of disclosure.
Of the financial interests disclosed, only those meeting or exceeding thresholds as established by the CIRC are required to be evaluated for financial conflicts of interest. The criteria below defines when reported financial interests are considered material* for research supported or funded by the corresponding organization. For FCOI review purposes, a financial interest is considered significant/material if it meets or exceeds the threshold when reported for either the preceding 12 months or anticipated in the next 12 months and exceeds the values below in the aggregate for a 12-month period.
CIRC Threshold for Reviewing Financial Interests, based on the type of Research Funding
| Funding Type | Applicable Threshold |
|---|---|
| PHS/NIH DOE Organizations that have adopted PHS regulations (e.g. AHA) | ≥$5,000 in remuneration or equity in a publicly traded entity, in the aggregate Any ownership interest or equity in a non-publicly traded entity Any receipts of income related to intellectual property rights and interests, regardless of the source (e.g. through WashU) An agreement with an entity that entitles an individual to future income/royalties related to intellectual property (IP) rights and the IP is used or evaluated in human studies research Travel for which the individual is either reimbursed for or paid for on the individual’s behalf (sponsored travel) that is related to their institutional responsibilities; this includes registration fees, accommodations, transportation costs, meals and other travel related expenditures. Travel sponsored or reimbursed by a U.S. government agency (local, state or federal) or a U.S. institution of higher education is excluded from review. Refer to the Travel Disclosure requirements for additional details. |
| All other funding sources/research activities (e.g. NSF, industry, departmentally funded, etc.) | ≥$10,000 in remuneration or equity in a publicly traded entity, in the aggregate 5% ownership in a publicly traded entity Any ownership interest or equity in a non-publicly traded entity Any receipt of income related to intellectual property rights and interests, regardless of the source (e.g. through WashU) An agreement with an entity that entitles an individual to future income/royalties related to intellectual property (IP) rights and the IP is used or evaluated in human studies research Other financial interests as may be defined and required by the research sponsor |
| Excluded from CIRC Review | Income from seminars, lectures, teaching engagements, service on advisory committees or panels paid by US federal/state/local government agency, or US institutions of higher education Income from investment vehicles, such as mutual funds and retirement accounts, as long as the individual does not directly control the investment decisions Invention disclosures or patented intellectual property, (unrelated to a licensing agreement) |
*Material interests, in the context of the Research COI policy, represent ‘Significant Financial Interests’ (including applicable exclusions) as defined by federal and state regulations and/or agency sponsor requirements. It may also include financial interests that exceed an agency’s de minimus requirements due to University policy (e.g. income for royalty related to IP rights licensed through WashU is considered a material interest).
Prior revisions: 09/28/23, 05/25/22, 8/24/12