Policies, Procedures and Guidelines

Travel Procedures and Guidance

Washington University has developed the following procedures and guidelines regarding the requirements to disclose travel by individuals involved in the design, conduct, or reporting of Public Health Services (PHS)-funded research, as required by the PHS regulations governing financial conflicts of interest (42 C.F.R. Part 50 and 45 C.F.R. Part 94).

Procedures

1. Applicability

WUSTL shall require individuals who meet the definition of a cover​ed individual and are involved in design, conduct, or reporting of PHS (e.g. National Institutes of Health)-funded research to disclose information about certain travel activities.

2. Disclosure Requirements

Individuals must disclose the occurrence of any reimbursed or sponsored travel that appear to be related to their institutional responsibilities and are paid for by an entity other than WUSTL, U.S. federal, state, or local government agencies, or other U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education.

Disclosure is required regardless of value for travel in which the individual is reimbursed by an outside entity and/or travel that is paid for on the individual’s behalf by an outside entity. Travel includes, for instance, registration fees, accommodations, transportation costs, and meals. Outside entities may include, but are not necessarily limited to, professional societies, foreign institutions of higher education, for-profit entities, and non-profit entities.

3. Frequency

Travel must be disclosed within 30 days after the travel activity.

4. Disclosure Process

Individuals will disclose travel using a disclosure form specifically designed for travel, and will not use the annual Financial Disclosure Statement. The disclosure form shall be submitted to the CIRC for review, either via email, fax, or campus mail.

The individual shall disclose:

  • The dates of travel
  • Destination
  • Entity that paid for the travel
  • Purpose of the trip
  • Travel paid for the individual’s spouse and/or dependent child(ren) by the entity

In order to remind individuals to disclose, an email will be sent on a monthly basis prompting the individual to disclose travel using the disclosure form included in the email.

5. Review
Review of travel disclosure forms will be handled in accordance with the Procedures for Determining and Managing FCOIs.

Guidance

a. Who must disclose travel?
Only those individuals who meet the definition of a covered​ individual and are involved in PHS/NIH funded research need to disclose travel.

b. What must be disclosed?

  • Travel for which the individual is reimbursed for by an outside entity
  • Travel that is paid for on the individual’s behalf by an outside entity
  • Includes any registration fees, accommodations, transportation costs, etc.
  • Disclosure is required regardless of value
    Examples of outside entities:

    • Professional societies
    • Foreign institutions of higher education
    • For-profit entities
    • Non-profit entities

c. What information needs to be disclosed?

  • The dates of travel
  • Destination
  • Entity that paid for the travel
  • Purpose of the trip
  • Was travel paid for your spouse and/or dependent child(ren) by the entity?

d. What does not need to be disclosed?

  • WUSTL (regardless of whether WUSTL is reimbursed for the travel by a third party),
  • U.S. federal, state, or local government agencies,
  • Other U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education

e. When must travel be disclosed?

Within 30 days after the travel activity.

f. Why is the amount/cost of the travel not needed?
The regulations do not require the University to ask for this information. In addition, if the entity paid for the travel directly, the individual may not know the amount or be able to easily obtain the amount.

g. How will travel be disclosed?

For those individuals required to disclose travel, they will be emailed each month and prompted to disclose any material travel using a disclosure form that will be included in the email. Then the individuals may email, fax, or send via campus mail to the CIRC for review.

h. When will travel be considered a conflict of interest?
Travel will be assessed on a case by case basis. In general, reimbursement for the actual cost of travel to meetings for professional societies/other non-profits or travel directly related to sponsored research activities will not be considered a financial conflict of interest.