Effective: 08/24/2012Revised:10/6/2023 Washington University (WashU) shall provide to any requestor written information about Financial Conflicts of Interest, which were determined to be a Financial Conflict of Interest related to research on or after August 24, 2012, as applicable and in accordance with federal regulations including 42 CFR 50 Subpart F, 45 CFR 94 and 2 […]
Subgrouping: Procedures
Financial Interest Disclosure Reviewing Thresholds
Conflict of Interest Review CommitteeEffective: August 24, 2012Last 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 […]
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
Last Revised Date 11/9/2023 1. Introduction The Conflict of Interest Review Committee’s (CIRC) procedures will comply with all applicable federal regulations and funding agency requirements. 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 […]
Timing of Disclosures
Original Effective Date 09/30/2003Last 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: Upon request by the Office of Research Integrity & Ethics (ORIE) or […]
FCOI Education Requirements
Effective: August 24, 2012Last Revised: September 28, 2023 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
Originally effective: August 1998Revised: September 28, 2023 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 non-compliance. […]
Travel Procedures and Guidance
View the Travel Procedures and Guidance on the Conflicts of Interest page.
Who is Required to Submit a Financial Disclosure
Original Effective Date 9/30/2003Last Revised Date 8/16/2018 a. All faculty with an academic appointment of instructor or higher on tenure or non-tenure tracks. b. Individuals, who by definition have independent responsibility for the design, conduct, or reporting of research at WU, which includes: c. Individuals involved in the design conduct or reporting of research at WU, regardless […]