Original Effective Date: September 30, 2003
Last Revised Date: September 28, 2023
External Professional Activities and Interests – Disclosure Requirements
Disclose all activities occurring in the preceding 12 months or anticipated in the next 12 months from the date of disclosure that appear related to an individual’s professional, academic or scientific expertise or institutional responsibilities, unless excluded below. The disclosure is to include compensated or uncompensated activities with for-profits, non-profits, foreign entities, and research activities not managed through WashU.
Institutional responsibilities are defined as an individual’s professional duties and responsibilities on behalf of the university and may include, but are not limited to, research or other scholarly inquiry, education, professional practices, clinical activities, administration, institutional committee membership, and service on panels such as internal review boards and data and safety monitoring boards.
All financial interests of the individual’s spouse/partner and dependent children must also be disclosed, regardless of value, if they could appear related to the individual’s institutional responsibilities. In addition, some activities require prior approval, which are denoted with an asterisk.
For reporting purposes, a foreign entity includes any entity whose physical location (or headquarters for those with international offices such as professional societies) 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.
The following is a non-exhaustive list of common activities and financial interests3 for the individual, spouse/partner or dependent children and whether they require disclosure.
EPA Disclosure Requirements – Activity Examples
| Activity Type | Required to Disclose | Not Required to be Disclosed1 |
|---|---|---|
| Appointments outside of WashU* | All academic, professional, scientific, or institutional appointments outside of WashU; includes any form of research oversight, teaching courses or student advisory activities · Includes honorary, courtesy, or adjunct appointments at foreign or domestic institutions · Contracts required2 Compensated appointment of spouse | Salary or other compensation paid by WashU |
| Employment in an entity other than WashU* | Includes any form of employment outside of WashU2 Compensated employment of spouse | |
| Board of Directors, 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 position2 Professional/Academic Societies: Serving on a board or as an officer of a foreign based academic or professional society (headquarters are not located in the U.S.) | Voluntary (uncompensated) service as an officer of a U.S. professional or academic society |
| Advisory Board Service | Service on an advisory board for a for-profit or not-for-profit entity, including service on scientific or medical advisory boards2 | Service on advisory committees or review panels for a U.S. Federal, state, or local government agency, U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with a US institution of higher education Professional/Academic Society: • Uncompensated service on board of an academic or professional society • General membership for any academic or professional society |
| Research: Conducting research not sourced or routed through WashU* | External PI role2 External engagement in the design, conduct or reporting of research, includes any involvement in research sufficient to warrant an authorship role2 • Copies of research contracts/grants for foreign entities are required; others may also be required upon request | Research supported and managed by WashU (applications and funding managed through WashU) |
| Services for non-U.S. entities – Scientific reviews or evaluation panels Includes Peer Review and Mentoring Activities | Thesis/Dissertation: Serving as a member of a thesis or dissertation committee at a foreign academic institution Grant reviewer for a foreign entity Providing journal/editorial reviews; serving as a journal editor if compensated | Thesis/Dissertation: Serving as an external member of a thesis or dissertation committee at a U.S. academic institution Reviewing proposals for a U.S. federal or state government sponsor, or a domestic non-profit organization Providing journal/editorial reviews; serving as a journal editor if uncompensated |
| Legal consulting and expert witness services | Providing scientific, technical, or ideological expertise in the context of legal or administrative actions, such as litigation, hearings, subpoenas or depositions; includes case or file reviews for medical malpractice claims Physicians and Health Professionals must obtain prior approval* | |
| Product Development or Evaluation Activities | Providing feedback, input, and recommendations for the design or modifications of a specific product or service of an entity2 | |
| Consulting Services not otherwise specified | Consulting activities with external entities2 | Consulting or mentoring (without effort) on a U.S federal grant Service on advisory committees or review panels for a U.S. Federal, state, or local government agency, U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with a U.S. institution of higher education |
| Speaking engagements | Speaking engagements, presentations, lectures, or educational sessions must be disclosed if compensated or other benefit is received (e.g. research funding gift or award, honorary title, data/resource access) • Physicians and Health Professionals at the School of Medicine are required to obtain prior approval for speaking engagements* | Income/activity from travel, seminars, lectures, or teaching engagements sponsored by: • U.S. federal, state, or local government agency, or • U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education |
| Authorship | Publishing agreements Book royalties | |
| Licensing /Product development agreements or Royalties for inventions/IP | Receipt of any income related to intellectual property rights (e.g. cash royalty payments), and includes: • Royalties from other academic Institutions • Royalties paid through WashU for intellectual property rights assigned to WashU An agreement with an entity, including WashU, that entitles an individual to future royalties but no income has been received | Invention disclosures or patents |
| Equity/Ownership interests in publicly or non-publicly traded entities | Ownership interest in a private or public entity (stocks, stock options, warrants, or other ownership interests regardless of value) Venture or Other Capital Financing: For privately held entities, information on venture or other capital financing may be required to be disclosed depending on funding agency requirements | 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 |
| Other compensated or voluntary activities | Activities related to institutional responsibilities or area of expertise not otherwise categorized above | Salary or other remuneration paid by WashU Uncompensated activities of spouse/partner or dependent children |
| Travel Use the travel disclosure form | Travel for which the individual is either reimbursed for or paid for on the individual’s behalf and includes registration fees, accommodation, transportation costs, etc. Additional details available here. • Only applicable to individuals involved in the design, conduct, or reporting of research sponsored or supported by these research funding agencies and organizations | Travel paid for by: • WashU • 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 |
Important information to include when disclosing external professional activities:
The following are not External Professional Activities in and of themselves, however it is important to ensure these attributes are clearly disclosed if they are expected or involved as part of an external activity. In most instances, prior approval of the external activity is required if it will involve one or more of the following attributes, even if the activity itself would not normally require prior approval (e.g. consulting).
| Access to external research resources* | Entity provides any resources, including financial support, equipment, or non-publicly accessible information or data for possible use at WashU |
| Use of WashU Resources* | 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 Creating an obligation on WashU (i.e. inviting or hosting students, trainees on campus) Donating equipment for use at WashU |
| Obligations on WashU* | Hosting, mentoring, and/or supervising any individuals or personnel from an entity at WashU as part of or resulting from the external professional activity |
| WashU Student/Staff/Trainee engagement* | Involvement of WashU students, staff or trainees in an external professional activity or with an external entity (i.e. includes but is not limited to recruitment/referral, employment, internship) |
| Other Gifts or Benefits | Any other forms of compensation, remuneration, or benefit received as part of the activity (e.g. gifts, spousal or familial financial support, living expenses, room and board, donations or unrestricted gifts for use at WashU) |
1 External activities related to academic appointment progression or otherwise excluded from disclosure may be required if the total time commitment associated with all external activities exceeds, or is likely to exceed, an average of one day per week (e.g. 20%) of a covered individual’s time. Covered individuals are responsible for monitoring all external professional time commitments whether or not they are required to be reported under this or other university policies.
2 Disclosure of Contracts
Personal contracts for external professional activities must be provided in the following circumstances:
- For activities with entities affiliated with countries of concern (China/Iran/Russia/North Korea)
- For all employment or appointments outside of WashU
- As requested by WashU
- Physicians and Health Professionals providing services to external entities
3 In the context of the Research COI policy, for reported financial interests; Material Interests represent ‘Significant Financial Interests’ (including applicable exclusions) as defined by federal and state regulations and/or agency sponsor requirements. It may also include financial interests that exceed an agency’s de minimus requirements due to University policy (e.g. income for royalty related to IP rights licensed through WU is considered a material interest).
* Denotes prior approval Required
Previously Revised: 09/28/23, 7/20/23, 8/16/18, 11/29/16, 4/13/15, 8/24/2012, 12/05/2006, 02/09/2006, 11/09/2005, 11/02/2004