Original Effective Date 08/2018


Allows for a delegate to be able to access and enter data for an individual’s disclosures:

  • Financial Disclosure Statements (FDS)
  • Research Disclosure Forms (RDF)
  • Travel Disclosures (only applicable to investigators involved in projects supported by entities adhering to PHS regulations such as NIH or AHA)
  • Expert Witness Disclosures (applicable to physicians and health professionals only)


Delegators’ Responsibilities

  • Must:
    • Submit their own (thereby certifying) Financial Disclosure Statements (FDS) and Research Disclosure Forms (RDF)
    • Retain full responsibility and accountability for all information entered and submitted in the disclosure forms.
    • Individually authorize delegates to enter information on their behalf
    • Maintain the accuracy of the delegate list as this is not automatically updated if the delegate leaves the department or university.
  • Must NOT:
    • Authorize delegates to submit the Financial Disclosure Statement or Research Disclosure Forms on his/her behalf.

Delegates’ Responsibilities

  • Allowed to:
    • Access authorized accounts through the COI Portal.
    • Enter information in all disclosures (financial, research, and travel).
    • Submit only travel or expert witness disclosures on behalf of a delegator.
    • View the last submitted financial and research disclosure, the last 12 months of reported travel, and the last 36 months of reported expert witness disclosures.
  • NOT Allowed to:
    • Submit the Financial or Research disclosures (FDS/RDF) on behalf of delegators (these forms must be certified by the individual)
    • Complete “action items” on behalf of delegators, such as accepting management plans.

Non-Adherence to Procedures

  • For accidental FDS/RDF submissions by a delegate, the Delegator or Delegate should immediately contact askCOI at 314-747-4181 or coi@wustl.edu to correct the issue
  • Failure to adhere to Delegator or Delegate responsibilities will result in removal of delegate access.

Additional Information

  • Only directly authorized delegates will have access to a person’s COI disclosures
  • Only individuals with an appointment at WU and access RMS via WUSTL Key can be a delegate