Material Financial Interest

Created 08/24/2012Last Revised Date 05/25/2022 The following outlines the CIRC’s Threshold for Reviewing Financial Interests. Reviewable against entities that have adopted PHS equivalent thresholds (e.g. PHS, DOE, AHA): ≥$5,000 in remuneration from an entity (includes non-profits), in aggregate ≥$5,000 equity in publicly traded entity Holding of any ownership interest or equity in a non-publicly traded […]

Dispute Resolution/Appeals Procedure

Original Effective Date 08/27/2002 Last Revised Date 08/24/2012 Introduction The WUSTL Research Conflicts of Interest Policy states “Unresolved disagreements concerning the application of this policy shall ultimately be referred for final resolution to a committee established by the chancellor or representative appointed by the chancellor.” This procedure outlines the necessary steps individuals shall take to resolve […]

Determining and Managing Research FCOIs Procedures

Original Effective Date 10/20/1993 Last Revised Date 8/24/2012 1. Introduction The following describes the Conflicts of Interest Review Committee’s (CIRC) procedures and considerations for a) reviewing individuals’ personal financial interests, b) determining whether there is a material financial interest, c) evaluating its relatedness to the research and risks, to determine if a financial conflict of interest […]

Timing of Disclosures

Original Effective Date 09/30/2003 Last Revised Date 05/25/2022 All faculty with an academic appointment of instructor or higher and all individuals, who by definition have independent responsibility for the design, conduct, or reporting of research at WashU are required to proactively submit a disclosure: at least annually; within 30 days of acquiring a new financial […]

Financial Interests to Disclose

Original Effective Date 09/30/2003 Last Revised Date 05/25/2022 All personal financial interests, and those of the individual’s spouse and dependent child(ren), that appear to be related to a covered individual’s institutional responsibilities at WashU must be reported, regardless of value. Institutional responsibilities are defined as an individual’s professional duties and responsibilities on behalf of the University. These […]

FCOI Education Requirements

Original Effective Date 08/24/2012 Last Revised Date 05/02/2015 Introduction The WUSTL Research COI Policy states “A covered individual must complete training in regard to this policy and applicable federal regulations as established by the University and/or applicable federal regulations.” Central to Washington University’s mission of fostering excellence in research is a commitment to ensure that individuals […]

Noncompliance Assessment Process and Potential Sanctions

Original Effective Date 08/01/1998 Last Revised Date 07/18/2013 1. Assessment When a potential failure to comply with WU’s policies and processes governing research conflicts of interests is identified, the CIRC Chair will conduct an assessment of the situation and make a determination as to whether the individual failed to comply and the extent of the […]

Who is Required to Submit a Financial Disclosure

Original Effective Date 9/30/2003 Last Revised Date 8/16/2018 a. All faculty with an academic appointment of instructor or higher on tenure or non-tenure tracks. Includes: Tenure-track faculty, Non-tenure-track faculty (Research, Clinical, Practice, Visiting appointments) May include: Adjunct or Emeritus if they have effort and are involved in research Does not typically include: Lecturers or Courtesy appointments b. Individuals, […]