EPA Disclosure Requirements - Activity Examples | Conflicts of Interest

Quick Links to Examples Below

Prior Approval Required
Appointments or Employment Outside of WashU
Board of Directors, Officer, Trustee or other Fiduciary Role
Advisory Board Service
External Research (not sourced through WashU)
Peer Review and Mentoring Activities
Consulting Services
Legal Consulting/Expert Witness
Speaking Engagements
Authorship, Book Royalties, Publication Agreements
Royalties for Licensing/Product Development
Equity/Ownership Interests
Travel
Other Activities

The first table below details EPAs that have a higher risk of overlap with an individual’s Institutional Responsibilities and require approval prior to initiating the activity. The second tables provides examples of common activities, and whether disclosure is required under one or more policy or if not reportable. The tables are not intended to illustrate the specific policies under which reported activities would be reviewed nor is a reportable activity necessarily indicative of a potential conflict.

Disclosure should include activities, regardless of remuneration, that appear to be related to an individual’s professional, academic or scientific expertise or institutional responsibilities, unless excluded below. All personal financial interests of the individual’s spouse/partner and dependent children must also be disclosed, regardless of value, if they could appear related/overlapping to the individual’s institutional responsibilities.

**For reporting purposes, a foreign entity includes any entity whose physical location (or headquarters for those with international offices such as professional societies) that is located outside of the U.S. An entity may also be designated by WashU or the U.S. government as foreign if it is owned or funded (in whole or in large part) by a foreign government regardless of location; this information is readily available as part of the disclosure process.

Prior Approval Required

Activity	Prior Approval Required
External Appointments or Employment Any employment with an external entity as well as all academic, scientific, or institutional appointments outside of WashU; includes any form of employment or engagement, research oversight, teaching courses or student advisory activities. Includes honorary, courtesy, or adjunct appointments at foreign or domestic institutions.	Yes
External PI Role Serving as Principal Investigator on research outside of WashU (research not sourced or routed through WashU as part of contractual agreement).	Yes
External Research Engagement Independent responsibility for the design, conduct or reporting of research not sourced through WashU, includes any involvement in research sufficient to warrant an authorship role.	Yes
External BOD, Officer, Trustee, or Other Fiduciary Role Service, position, or role involving a fiduciary responsibility to an outside entity including service as member of the board of directors, an officer, a trustee, or any other executive or management position.	Yes
Involving WashU Resources Any EPA that includes using WashU resources beyond basic office equipment and supplies to fulfill obligations under the EPA, such as providing: • Non-publicly available data, information or materials • Specialized equipment or software • Physical space or internal funds	Yes
Involving WashU Students or Staff Any EPA that includes employing undergraduate or graduate students, or University staff in an EPA creating overlapping supervisory/authoritative relationships.	Yes
External Research Resources Any EPA providing access to resources, including financial support, personnel, equipment, or non-publicly accessible information or data for possible use at WashU.	Yes
Creates Obligation on WashU Any EPA that creates obligations on WashU including hosting students/visiting researchers/post-docs or involves the dissemination/use of confidential, proprietary, or unpublished research data from WashU (without a formal agreement between WashU and entity).	Yes

Appointments or Employment Outside of WashU

Typically a contractual relationship involving a scope of responsibilities being provided in exchange for remuneration; stipulating the responsibilities, payment or remuneration terms and arrangement, rules of the workplace, and is recognized as employment by the government (as opposed to a consulting contract).

Appointments or Employment Outside of WashU	Financial Interests COI Policies	EPA Full Disclosure	EPA Prior Approval	Not Reportable
A) Part time instructor also holds a part-time position in a local startup company	X	X	X
B) Faculty member with 9 month appointment works as scientist in a research lab during the summer	Paid	Unpaid	X
C) Spouse works for a company that is sponsoring research in the faculty member’s lab	X	X
D) Spouse works for company that does business with WU but not in the same school as faculty member				X
E) Teaching at a foreign institution	Paid	Unpaid	X
F) Honorary appointment at an academic institution	Paid	Unpaid	X

Board of Directors, Officer, Trustee, or other Fiduciary Role

Typically involves providing guidance and governance to a company or entity (including non-profits). BOD service may or may not involve remuneration or direct management of operations.

Board of Directors, Officer, Trustee, or other Fiduciary Role	Financial Interests COI Policies	EPA Full Disclosure	EPA Prior Approval	Not Reportable
A) Unpaid Board of Directors (BOD) member for a company that works in the same space as the individual’s area of expertise		X	X
B) Serves as Chief Scientific Officer for a start-up	Paid	Unpaid	X
C) Spouse serves as CEO of discloser’s start-up	X	X
D) Unpaid BOD member for local charity related to the individual’s area of academic expertise		X	X
E) Unpaid BOD member for non-profit with no affiliation with WashU or the individual’s area of academic expertise				X
F) Paid BOD member of a company that supports research at WashU, but not the individual’s specific research	X	X	X
G) Volunteer on BOD for U.S professional society				X
H) Volunteer on BOD for professional society that has headquarters outside of U.S.		X	X
I) Hires graduate students to work at a company for which they serve on the board and will supervise student	Paid	Unpaid	X

Advisory Board Service

Typically serving with a group of individuals in providing scientific, technical, or ideological expertise. Advisory Board services may be specific to a particular project or concept or broadly applied to an area of science.

Advisory Board Service	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Serving on an advisory board to a company related to the individual’s area of academic expertise	Paid	Unpaid
B) Serves on an advisory board or review panel paid for by US government agencies (e.g. review panel for NIH)			X
C) Serving on board of a foreign academic or professional society (society’s headquarters are not located in the U.S., considered foreign entity**)	Paid	Unpaid

External Research (not sourced through WashU)

Substantial involvement in the design, conduct, or reporting of research activities not contracted or managed through WashU, including serving as PI. Typically any involvement sufficient to warrant an authorship role is deemed substantial involvement.

External Research (not sourced through WashU)	Financial Interests COI Policies	EPA Full Disclosure	EPA Prior Approval
A) Uses WashU licensed software to analyze data from research conducted on behalf of an external entity		X	X
B) Arrangement to serve as PI, co-PI or investigator on a grant from a foreign government, unpaid		X	X
C) Serving as an national PI for a multicenter clinical trial	Paid	Unpaid	X
D) Paid effort on a grant at University of Pittsburgh over the summer	X	X	X

Peer Review and Mentoring Activities

For non-U.S. activity disclosures, select “Services for non-U.S. entities in the disclosure form”

Activities typically associated with peer and student engagements such as grant proposal reviews, mentorship or thesis/dissertation service, or editorial activities.

Peer Review and Mentoring Activities	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Serving as an external member of a thesis or dissertation committee at a foreign academic institution.		X
B) Serving as an external member of a thesis or dissertation committee at a U.S. academic institution.			X
C) Serving as mentor on a post-doc’s fellowship at a foreign university		X
D) Serves on a grant review panel for an International research foundation (headquarters outside of the U.S.)	Paid	Unpaid
E) Reviewing grant applications for a funding agency of a foreign government	Paid	Unpaid
F) Peer review of articles or grant proposals for domestic non-profit or U.S. government sponsor (local/state/fed)			X
G) Serves on an study section for US government agencies (e.g. NIH)			X
H) Editorial services for journal/professional organizations	Paid	Unpaid

Consulting Services

Providing scientific, technical, or ideological expertise. Consulting services may be specific to a particular project or concept or broadly applied to an area of scientific expertise.

Consulting Services	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Paid consultant to provide scientific expertise to a company	X	X
B) Spouse of faculty member in computer sciences receives compensation for consulting for a software company	X	X
C) Consulting for a U.S. government agency (e.g. FDA)			X
D) Serves as ‘consultant’ on an NIH grant awarded to University of Pittsburgh, no effort			X
E) Serves as a consultant for an art museum in preparation for an exhibit	Paid	Unpaid

Legal Consulting/Expert Witness

Consulting services specifically related to legal engagements such as litigation, patent disputes, medical malpractice suits/case review, or similar activities.

Legal Consulting/Expert Witness	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Serves as a paid expert witness in a civil lawsuit	X
B) Provides consulting services in reviewing medical records in a class action lawsuit	X
C) Law professor provides pro-bono legal services to underserved populations in the St. Louis Area		X
D) Reimbursed for expenses to serve as a witness in vehicular accident near campus			X

Speaking Engagements

Providing lectures, talks, keynote speeches, presentations of research results.

Speaking Engagements	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Paid speaking fee from a company for providing an educational talk (non-promotional)	X	X
B) Receiving compensation as key note speaker at an event hosted by a professional association	X	X
C) Presenting research at an event sponsored or hosted by an academic institution outside of the U.S.	Paid	Paid
D) Presenting research at an event sponsored or hosted by a professional association whose headquarters is outside of the U.S.	Paid	Paid
E) Presenting research at an event sponsored and hosted at MIT			X

Authorship, Book Royalties, Publication Agreements

Activities relating to authorship or publication agreements either electronic or print.

Authorship, Book Royalties, Publication Agreements	Financial Interests COI Policies	EPA Full Disclosure	Not Reportable
A) Receives book royalties for college textbook used at other universities	X
B) Reviews and edits press release on clinical trial results for an entity	Paid	Unpaid
C) Receives an advance to write a fictional mystery novel			X

Royalties for Licensing/Product Development

Agreements that have or will result in compensation related to the intellectual property/copyrighted materials or the development of IP/copyrights

Royalties for Licensing/Product Development	Financial Interests COI Policies	EPA Full Disclosure
A) Royalties from other academic Institutions for discloser’s Intellectual Property	X	X
B) Royalties paid through WashU for intellectual property rights from a license agreement between WashU and a commercial company	X	X
C) An agreement for future royalties for intellectual property (regardless of entity)	X	X

Equity/Ownership Interests

Any ownership or investment in an entity regardless of value or vested/unvested. This includes all forms of equity either public or private including stocks, options, bonds, notes.

Equity/Ownership Interests	Financial Interests COI Policies	EPA Full Disclosure	EPA Prior Approval	Not Reportable
A) Ownership interest in an private or public entity (stocks, stock options, warrants, or other ownership interest regardless of value)	X	X
B) Income from investment vehicles (such as mutual funds, retirement accounts, and blind trusts) as long as the individual does not have direct control over the investment decisions				X

Travel

Sponsored or reimbursed travel by an entity and includes transportation, food, lodging, registration fees/costs.

Travel	Financial Interests COI Policies	Not Reportable
A) Company directly pays for airfare for a NIH funded investigator to attend a professional speaking engagement	X
B) WashU covers hotel and food costs for a faculty member attending a conference		X
C) Travel paid for/sponsored by U.S. government agencies/academic institutions		X
D) Travel paid for/sponsored by foreign government agencies/academic institutions and you receive DOE funding	X

Other Activities

Activities that are not best described above or circumstances/conditions that are not activities in and of themselves but may have a significant impact on the potential overlap of a reported activity to WashU.

Other Activities	Financial Interests COI Policies	EPA Full Disclosure	EPA Prior Approval	Not Reportable
A) Volunteers time at a local food pantry or homeless shelter				X
B) Using data from consultation activities to support a WashU grant application		X	X
C) Receives lab space and lab staff at another university but no direct personal remuneration		X	X
D) Agrees to hosting doctoral students at WU as part of an academic appointment contract at a foreign institution		X	X
E) Receives lab space and resources at another university along with a stipend	X	X	X
F) Receives daily living allowance while reviewing PhD candidates at a foreign institution	X	X
G) Research activities being managed and supported through WashU				X
H) Hires lab staff to work part-time for discloser’s start-up		X	X
I) Hires WashU students to work on research involved with an external professional activity		X	X
J) Faculty member in the Sam Fox School of Design and Visual Arts is compensated for art exhibit	X	X