EPA Disclosure Review Process

Original Effective Date: 9/1/2023
Last Revision Date: 9/1/2023

EPA Administrative Review
External Relations Associate Expedited Review
School/Department Review
Dean Review
Questions?

External Professional Activities (EPA) Administrative Review

The Office of Research Integrity and Ethics (ORIE) shall conduct initial assessments of all External Professional Activities (EPAs) for compliance with institutional policies and School/Department review requirements. ORIE shall identify and communicate activities needing review and/or approval by the Designated Reviewers or other individuals, as prescribed by the EPA Policy and corresponding procedures.

Administrative Review Process

  1. Determines which EPAs meet the designated reviewer thresholds for review.
  2. Obtains clarifying information as needed to facilitate review.

ORIE Administrative Approval Process

  1. Conflict of Interest (COI) program staff will conduct an administrative EPA disclosure review under delegated authority by the Schools in the following situations:
    • Activities already reviewed as a prior annual (full EPA) disclosure within the last 18 months or as a Prior Approval Request (PAR) within the last 6 months
    • No activities reported relate to ‘self’ (reported only spouse or dependent children)
    • Activities involve fixed fee licenses
    • Activities are not personal or are not reportable, e.g., activities performed for the University or unrelated to professional expertise
    • Activities that have ended
    • Activities are investments in publicly traded entities (for non Institutional Officials (IO) or for IOs with less than $100,000 per entity)
    • Book royalties
    • Academic journal editorial services
    • Below 250 hours total time commitment
  2. All other EPA disclosures will be elevated to the External Relations Associate (ERA).
  3. All PARs are elevated for review to the ERA.

External Relations Associate (ERA) Expedited Review

  1. External Relations Associate reviews elevated EPA disclosures and PARs to determine if further elevation to Designated Reviewers/Deans is appropriate. The ERA:
    • Determines which EPAs meet the designated reviewer thresholds for review.
    • Obtains clarifying information as needed to facilitate review.
  2. EPA disclosures and PARs that cannot be administratively closed are elevated to designated reviewers for evaluation.

School/Department Review

  1. EPA disclosures and PARs are elevated to designated reviewers for evaluation when the following are reported (not exhaustive):
    • All external employment
    • All external academic, institutional or government appointments
    • All research conducted outside of WashU
    • Fiduciary roles in an external entity, e.g., board or officer appointments
    • Founder/co-founder role for a start-up or when there is a change such as licensing or funding (e.g. SBIR/STTR)
    • Time commitments are greater or equal to 250 hours of EPA per year for all activities
    • New management plans issued by CIRC or ICOI if there was a substantive change to WashU role and the designated reviewer has not been copied on the management plan
    • Engagement with countries of concern (as defined by the US State Department), currently Russia, China, North Korea, Iran
    • Any activities indicating significant overlap or high risk for conflict of commitment (this includes: external research resources, use of WashU resources, involvement of WashU students or staff, and anything that would create an obligation on WashU such as hosting visitors)
    • Anything else that cannot be administratively closed or approved
  2. For disclosure and reviews determined to not have any conflict of commitment, outcome is routed back to External Relations Associate.
  3. For disclosure reviews determined to have conflict of commitment:
    • School/Department notifies faculty and External Relations Associate if management is required and specific steps to be taken
  4. For all Prior Approval Requests (PARs), evaluations are routed to External Relations Associate for closeout and faculty notifications.

Dean Reviews

  1. EPA disclosures and PARs are elevated to the School’s Dean for evaluation when:
    • Activities reported are: external appointments/research/employment that involve any countries of concern (China, Iran, North Korea, and Russia)
      • Activities are only elevated following review and approval by the applicable Designated Reviewer.
  2. For disclosure and reviews determined to not have any conflict of commitment, outcome is routed back to External Relations Associate.
  3. For disclosure reviews determined to have conflict of commitment:
    • School/Department notifies faculty and External Relations Associate if management is required and specific steps to be taken
  4. For all PARs, evaluations are routed to External Relations Associate for closeout and faculty notifications.

Disclosure and Review Questions

For all disclosure review questions, contact the Conflicts of Interest (COI) Office  coi@wustl.edu or 314.474.4181.