Washington University recognizes that activities and relationships with external organizations may further the professional development, foster beneficial collaborations and provide professional satisfaction. As part of the External Professional Activities policy, a structured prior approval process enables schools to advise individuals on how best to design and navigate certain external relationships. Most activities do not require prior approval, only those having a higher risk of creating potential conflicts of commitment.
Requests for Prior Approval of External Professional Activities serves two key purposes:
- Provides a concise mechanism for covered individuals to inform the University of a potential new EPA (avoids updating the full disclosure).
- Enables the University to proactively address overlap between a proposed EPA and University activities (avoids burdensome changes to the activities or agreements after they have been initiated).
The table below provides an overview of the specific activities requiring prior approval:
a) 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.
b) Mentoring activities, or serving on a thesis/dissertation committee at academic institutions (without any affiliated appointment).
|External PI Role:
Serving as Principal Investigator on research outside of WashU (research not sourced or routed through WashU as part of contractual agreement).
|External Research Engagement:
a) Performing research at or on behalf of another entity (including academic or research institutions, government, or non-profit) not within the scope of WashU research activities.
b) Consulting or mentoring on a U.S. federal grant outside the University (with no effort).
|External Fiduciary Role:
a) 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.
b) Serving on board or as officer of a U.S. academic or professional society.
|Involving WashU Resources:
Any EPA that includes using University resources, equipment or space to fulfill obligations under an EPA beyond basic office equipment and supplies; including enabling an entity’s personnel to use WashU equipment or space.
|Involving WashU Students or Staff:
a) Any EPA that includes employing undergraduate or graduate students, or University staff in an EPA creating overlapping supervisory/authoritative relationships.
b) Activities unrelated to a Covered Individual’s professional, academic, or scientific expertise (e.g. owning a rental property, other unrelated volunteer work).
|External Research Resources:
Any EPA providing access to resources, space, or services made available to individuals such as lab space, personnel, and research data.
|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).
|Additional EPA as may be required by a Dean.
|For Physicians and Health Professionals:
Expert Witness Services including any expert witness consultation or testimony (per Expert Witness Policy)
|For Physicians and Health Professionals:
Entity-supported educational lectures as defined by the Clinical COI Policy, including CME and non-CME entity-sponsored events.
|For Health Professionals:
Consulting or other professional services provided to an Entity (as defined by the Clinical COI Policy)
Personal Contract Requirements
In certain circumstances, covered individuals will be required to provide a copy of the personal contract associated with an External Professional Activity. Contact the organization if you are unable to locate the agreement, or do not have a written agreement, to obtain a copy or begin the process of establishing a written contract.
The University does not formally approve your personal agreements/contracts and will not be a party to a personal agreement; however, they may be reviewed to advise you on best practices and alignment with institutional or regulatory requirements. At a minimum you can anticipate providing contracts for:
- Any appointments and/or employment with a foreign entity including agreements for activities or resources provided by or on behalf of a foreign entity. Refer to Personal Agreements with a Foreign Entity for best practices.
- For Physicians and Health Professionals: personal contracts with medical/healthcare entities. See additional guidance in the Clinical Conflict of Interest Policy.
It is recommended you submit your contract with your Prior Approval Requests; however, it can be submitted without one. It may be required to complete the review. Contract reviews focus on compliance with WashU policies and generally include:
- Clarity of Scope/Responsibilities (e.g. clearly defined scope of work)
- Time Commitments (e.g. set cap on hours/effort complying with Consulting Privileges Policy)
- Clarity of Financial Terms (e.g. all remuneration/benefits delineated)
- IP Assignment Requirements (e.g. alignment with WashU IP Policy)
- Authorship Requirements (e.g. not implying activity was part of WashU role)
- Indications of a WashU obligation (e.g. hosting visitors or students at WashU)
- Inclusion of statement the agreement is a personal agreement.
If needed, provide a translated version for non-English contracts, either by an independent third-party or using software.
Submitting Prior Approval Requests
- You are encouraged to submit requests at least 30 to 60 days before the anticipated start date to ensure the review does not create a delay for initiating an activity.
- Submit the Prior Approval Request using the “Prior Approval Request for External Activities” located on the Conflict of Interest disclosure home page.
- The Request form is entity specific, meaning each request must be for one specific entity.
- You can list multiple activities, so long as they are all for that same entity.
- You can have more than one request under review at that same time. Use the ‘Current Status & History’ on the menu to track the status of requests as well as review any request submitted in the last 24 months.
- Following submission of the request, the COI Office will complete an initial review; and if meeting criteria, route the request to the appropriate Designated Reviewer within the your school.
- The Designated Reviewer will complete an assessment, follow up for additional information as needed, and address any overlap of the proposed activity with the individual’s institutional obligations that could create a conflict of commitment.
- If required, approvals by the Designated Reviewer will be elevated to the Dean’s Office for final approval and evaluation.
- After all reviews are complete, you will receive the final determination of the review, including any management deemed necessary to address overlap creating a conflict of commitment.
- Approved activities are automatically populated to your full External Professional Activities Disclosure, eliminating the need to re-enter the information when completing your full disclosure.
For any questions on the prior approval process or the External Professional Activities policy, contact your Designated Reviewer or askCOI at 314-747-4181 or email@example.com.