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If you have other browser questions or technical issues, contact the Service Desk at 314.933.3333
For form and policy questions, at email@example.com or 314.747.4181
For technical support such as help with your WUSTL Key or browser, contact the Service Desk at 314.933.3333
If your Financial Disclosure Statement button is gray, then you have recently submitted a disclosure and it is still under review. If you need to add a new interest or other change to your disclosure, simply at firstname.lastname@example.org or 314.747.4181
If your Research Disclosure button is gray, then you are not required to submit any research projects at this time. COI will contact you if you need to complete a Research Disclosure.
If you have other form questions, simply at email@example.com or 314.747.4181
All faculty with an academic appointment of instructor or higher on tenure or non-tenure tracks.
Individuals, who by definition have independent responsibility for the design, conduct, or reporting of research at WUSTL.
Individuals involved in the design, conduct or reporting of research at WU, regardless of role, who:
- Are entitled to receive remuneration from a licensing agreement
- Hold equity ownership in a non-publicly traded entity
Any other individual who, regardless of title or position, has or may have independent responsibility for the design, conduct, or reporting of the research.
Subrecipients who defer to WUSTL’s policies and process and who are involved in the design, conduct, or reporting of research.
Institutional officials that do not disclose directly to the Chancellor.
Faculty physicians who have a full or part-time appointment with WUSM and fellows. It does not include voluntary faculty.
Non-faculty Health Professions including full and part-time WUSM nurse practitioners, physician assistants, clinical nurse specialists, certified registered nurse anesthetists, certified nurse-midwifes, occupational therapists, physical therapists and pharmacists.
All individuals in a position to control the content of a CME activity (planning committee members, speakers, moderators, authors, etc.)
For additional details concerning who is required to submit a Financial Disclosure Statement, review the applicability section of the Research Conflicts of Interest Policy, the Institutional Conflict of Interest Policy, the Clinical Conflicts of Interest Policy, the CME Disclosure of Interest Policy, or at firstname.lastname@example.org or 314.747.4181
Examples of reportable financial interests include, but are not limited to, any form of monetary compensation, royalties, licensing, or product development agreements; and/or equity or ownership in an entity. This includes financial interests with any for-profit, non-profit, professional society, foreign academic/research institution, foreign government, or personal remuneration for research activities not managed through WU.
For specific details on what needs to be disclosed, visit Financial Interests to Disclose.
- Salary or other remuneration paid by WashU
- Service on advisory committees or review panels paid for by U.S. government agencies
- Income from travel, seminars, lectures, or teaching engagements sponsored by: U.S. federal, state, or local government agency, orU.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education
- Invention disclosures or patents
- 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
- Expert witness services related to medical malpractice litigation
- Travel paid for by:
- 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
For specific details on what does not need to be disclosed, visit Financial Interests to Disclose.
Financial disclosures are required by federal law and University policy, enabling the University to manage conflicts of interest related to research or clinical activities.
To learn more about Research Conflicts of Interest, visit the OVCR website.
To learn more about Clinical Conflicts of Interest, visit the CCOI website.
To learn more about CME Conflicts of Interest, review the CME COI policy.
To learn more about Institutional Conflicts of Interest, review the ICOI policy.
If you have additional questions regarding why you are being asked to disclose your financial interests, at email@example.com or 314.747.4181
Why am I required to disclose my spouse’s financial interests, even if my spouse is also employed at Washington University?
University policy and federal regulations require disclosure of all personal financial interests and those of family (defined as spouse/partner and/or dependent children) that appear to be related to the discloser’s institutional responsibilities.
For the purposes of determining conflicts of interest, spousal financial interests are considered one’s own interests. This is the case whether your spouse works for Washington University or any other employer.
For additional details concerning what financial interests you are required to disclose, review the Financial Interests to Disclose section of the Research Conflicts of Interest Policy and Guidelines, or at firstname.lastname@example.org or 314.747.4181
You should complete the Financial Disclosure Statement annually, within 30 days of changes to your financial interests, or when you initiate new research projects.
If you have previously completed a Financial Disclosure Statement, you will be reminded when it is due. If you are a new faculty member, you will also be notified shortly after your hire date.
If you have additional questions concerning when you must complete a Financial Disclosure Statement, simply at email@example.com or 314.747.4181
There are four disclosure statements in RMS: Financial Disclosure Statement; Research Disclosure; Travel Disclosure; Expert Witness Disclosure.
A Financial Disclosure Statement must be completed annually by anyone who is considered a Covered Individual.
A Research Disclosure is only required when prompted by research administration.
Travel Disclosures are only required from covered individuals involved in the design, conduct, or reporting of research funded by agencies adhering to PHS regulations.
Expert Witness Disclosures are only required from WUSM physicians and health professionals involved in providing expert witness testimony.
If you have additional questions concerning disclosure statements, contact firstname.lastname@example.org or 314.747.4181
Anyone who is required to complete a Financial Disclosure Statement must also complete Financial Conflicts of Interest (FCOI) Education every four years. FCOI education will automatically be assigned and appear on your Me page in Learn@Work.
Learn more about FCOI Education on the OVCR website.
If you have additional questions concerning FCOI Education, simply at email@example.com or 314.747.4181
About 80% of RMS users have no financial interests to disclose, and can complete their FDS within minutes by answering “no” to two simple questions on the Financial Disclosure Statement landing page.
Login to RMS to complete your FDS.
Download the COI Nothing to Disclose Quick Guide to learn more about completing the Financial Disclosure Statement in RMS.
If you need to disclose a new financial relationship, simply login to RMS, navigate to your Financial Disclosure Statement, and add a new Entity.
If your Financial Disclosure Statement button is gray, then your most recent disclosure statement is still under review. If you need to add a new interest or other change to your disclosure, simply at firstname.lastname@example.org or 314.747.4181
Download the COI Disclosure Entry Quick Guide to learn more about completing the Financial Disclosure Statement in RMS.
If you have recently submitted a Financial Disclosure Statement but need to add an interest and/or make other changes, simply to update by contacting email@example.com or 314.747.4181
Possibly. You will be contacted if a Research Disclosure is required. Unless required, the Enter/Update button next to the Research Disclosure will be gray and unavailable for selection.
Yes. Washington University recognizes that disclosure information is sensitive, and it is held securely and confidentially.
RMS is a secure website with very limited access, and only authorized individuals with the appropriate security access will be able to review your information.
The Committees responsible for evaluating financial disclosures in the four conflict of interest programs review each Disclosure for completeness and potential conflicts of interest. Potential conflicts may also be reviewed by the Conflict of Interest Review Committee.
Washington University recognizes that disclosure information is sensitive, and it is held securely and confidentially.
If you have additional questions concerning who will have access to your information, simply at firstname.lastname@example.org or 314.747.4181
For Institutional Officials
Institutional officials are determined by title and include Deans, Department Chairs, and Department Heads and Division Chiefs at the School of Medicine.
According to Washington University’s ICOI Policy, an ICOI exists whenever the financial interests of the University or the personal financial interests of an Institutional Official (IO) either affect, or reasonably appear to affect, the design, conduct, reporting, review, or oversight of research. Examples of ICOIs include research studies which:
- Evaluate a technology licensed by the University in exchange for equity and / or a promise of future royalties.
- Are led by faculty direct reports of a financially-conflicted IO, regardless of whether the IO serves as an investigator on the research.
Other COI and Programs Questions
There are four COI programs at Washington University:
The Research COI (RCOI) program seeks to assure that the objectivity and integrity of the university research, training, or other activities are not compromised or perceived to be compromised by considerations of personal gain or financial benefit.
RCOI employs strategies to manage financial conflicts of interest to assure the objectivity and integrity of research. The essential components of the RCOI program are disclosure, review, assessment and determination, and management of conflicts of interest.
To learn more about research conflicts of interest, visit the OVCR website.
The Clinical COI (CCOI) program seeks to ensure that Washington University and its physicians and health professionals avoid conflicts of interest or the appearance of conflicts of interest between their individual financial interests and the best interests of their patients.
To learn more about clinical conflicts of interest, review the CCOI Policy.
The Institutional COI (ICOI) program seeks to ensure that institutional conflicts of interest are managed so that they do not compromise, or reasonably appear to compromise, the integrity of the University’s research mission.
To learn more about institutional conflicts of interest, review the ICOI policy.
The Continuing Medical Education COI (CME COI) program seeks to ensure balance, independence, objectivity, and scientific rigor in all Continuing Medical Education (CME) activities that it provides and credits.
To learn more about CME conflicts of interest, review the CME COI policy.
With RMS, there is no need to complete separate forms for each program. All programs are able to review your Financial Disclosure Statements, Research Disclosures, and Travel Disclosures.
A research conflict is a situation in which it is reasonably determined that a material financial interest could directly and significantly affect the design, conduct, or reporting of research.
An institutional conflict is generally created when an institutional official’s financial interests can be affected by the outcome of research led by their faculty direct reports. An ICOI is also created when the University’s financial interests can be affected by the outcome of the research.
A clinical conflict of interest exists what a physician or health professional (or his/her immediate family member) has a financial relationship with an entity, and the physician or health professional is in a position to affect a patient’s decision and/or consent to the use of that entity’s products or services.
In accordance with ACCME criteria, circumstances create a CME conflict when an individual has an opportunity to affect CME content about products or services of a commercial interest with which he/she or his/her spouse/partner has a financial relationship.
With RMS, all COI programs are able to review your Financial Disclosure Statements, Research Disclosures, and Travel Disclosures.
Each COI office will be able to see the outcome of issue review and resolution posed by another COI office, and will coordinate when an issue is identified with the most appropriate office taking the lead.