Washington University has developed several policies and programs to ensure financial activity and external professional activities do not compromise or appear to compromise the objectivity and integrity of education, research, and clinical care at the University.
Research Conflicts of Interest (RCOI) Program
The RCOI program seeks to assure that the objectivity and integrity of the researcher, university, and academic research, training, or other activities are not compromised or perceived to be compromised by considerations of personal gain or financial benefit.
RCOI seeks to develop strategies to effectively and successfully 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 the RCOI program and/or review RCOI policies and guidelines, visit the OVCR website.
External Professional Activities (EPA) Policy
Washington University is implementing a new External Professional Activities (EPA) Policy to align with updated requirements from federal funding agencies and enable Schools/Departments to assess for conflicts of commitment. This policy supplements existing financial disclosure requirements established under WashU’s current conflicts of interest policies.
- All faculty must disclose external professional activities (EPAs) conducted with entities other than Washington University, even if individuals are not compensated for these activities.
- Some activities may require Department/School approval prior to engaging in the activity.
Learn More
External Professional Activities Policy
School Specific Guidance
Guidance for EPA Designated Reviewers
Conflict of Interest in Clinical Care (CCOI) Program
The 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 activities and the best interests of their patients.
To learn more about CCOI, Review the Clinical Conflict of Interest Policy.
Continuing Medical Education (CME COI) Program
The 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.
Institutional Conflict of Interest (ICOI) Program
The 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 primary missions, including the safety and integrity of its research mission.
To learn more about ICOI conflicts of interest, review the ICOI policy.
Organizational Conflicts of Interest (OCI)
OCI is a supplemental process to other COI policies including the Individual COI Policy, the Institutional COI Policy, and the EPA Policy. This supplemental process address WashU researchers having a potentially unfair competitive advantage over other applicants in pursuing research funding opportunities or impaired objectivity in the implementation or conduct of the research.
To learn more about Organizational Conflicts of Interests, review the OCI process.
Procurement and Conduct of Business
These policies address requirements for employees conducting business on behalf of Washington University to ensure such actions are responsible, objective, and ethical. This includes the conduct of procurement action involving related organizations including affiliates of WashU.
Learn More
Procurement Policy
Code of Conduct
Officer and Staff Conflict of Interest Policy
Other Policies at Washington University
Pharmaceutical and Medical Device Industry Policy — Interaction with Industry Representatives
University’s Relationship with a Faculty Start-up Company
Faculty Investments in Ambulatory Treatment and Diagnostic Facilities
Expert Witness Testimony Policy
Fact Testimony Policy for WUSM Employees
Conflict of Commitment (For Washington University Staff Employees)