Travel Disclosure

Original Effective Date 08/24/2012
Last Revised Date 05/25/2022

Individuals who meet the definition of a cover​ed individual and are involved in the design, conduct, or reporting of PHS-funded research (e.g. National Institutes of Health) are required to disclose information about certain travel activities.

Travel Disclosures are only required for covered individual who have had travel reimbursed or paid for by an outside entity. Travel should be disclosed when the aggregate value of sponsored or reimbursed travel exceeds an estimated $5,000 for an entity in the previous 12 months.

Log into RMS to complete a Travel Disclosure.

Download the Travel Disclosure Entry Quick Guide to learn more about completing the travel disclosure in RMS.

Travel Disclosure Guidance

A. Who must disclose travel?
B. What must be disclosed?
C. What information needs to be disclosed?
D. What does not need to be disclosed?
E. When must travel be disclosed?
F. Why is the amount/cost of the travel not needed?
G. How will travel be disclosed?
H. When will travel be considered a conflict of interest?
I. Helpful Tips
J. What agencies require travel reporting?

A. Who must disclose travel?

Individuals who meet the definition of a covered individual and as applicable under funding agency requirements are required to disclose travel.

B. What must be disclosed?

Disclosure is required when the aggregate value of sponsored or reimbursed travel exceeds an estimated $5,000 for an entity in the previous 12 months.

  • Travel for which the individual is reimbursed for by an outside entity
  • Travel that is paid for on the individual’s behalf by an outside entity
  • Includes any registration fees, accommodations, transportation costs, etc.
    • Examples of outside entities:
      • Professional societies
      • Foreign institutions of higher education
      • For-profit entities
      • Non-profit entities

C. What information needs to be disclosed?

  • Entity Name: Name of outside paying entity.
  • Purpose of trip: Select from the drop-down menu the purpose of the trip. Select ‘Other’ if the purpose of your trip isn’t a pre-defined option.
  • Destination: Provide the city and state (for domestic travel) or city and country (for international travel) where the activity took place.
  • Duration: Provide the number of days associated with the reimbursed travel from the date of departure to the date of return, which should not include personal days.
  • Travel Paid: Check each applicable checkbox to indicate if your own, your spouse/domestic partner’s, and/or dependent children’s travel expenses were covered for the trip.

D. What does not need to be disclosed?

Travel paid for by:

  • WashU (regardless of whether WashU is reimbursed for the travel by a third party),
  • 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

E. When must travel be disclosed?

You may choose to disclose by either:

  1. Disclosing each trip for an entity once an estimated aggregate value of $5,000 is reached.

OR

  1. Disclosing each trip as it occurs regardless of estimated value. (i.e. submit all trips from the last 30 days so as to not need to track value)

F. Why is the amount/cost of the travel not needed?

The regulations do not require the University to ask for this information. In addition, if the entity paid for the travel directly, the individual may not know the amount or be able to easily obtain the amount.

G. How will travel be disclosed?

For those individuals required to disclose travel, they will be emailed each month and reminded to disclose any material travel using the Travel Disclosure form via the Research Management System (RMS).

H. When will travel be considered a conflict of interest?

Travel will be assessed on a case-by-case basis. In general, reimbursement for the actual cost of travel to meetings for professional societies/other non-profits or travel directly related to sponsored research activities will not be considered a financial conflict of interest.

I. Helpful Tips

  • You may add trips on an ongoing basis as trips occur and not submit the form for CIRC review until the aggregate value of $5,000 is reached within a 12-month period.
  • Alternatively, if you don’t want to track the value of the trips, you may add trips on an ongoing basis and submit the form once a month.
  • You do not need to submit a separate disclosure form for each entity, all trips paid by various entities can be submitted on the same form.
  • When calculating duration, only include the days directly related to the sponsored or reimbursed travel, do not include personal days (i.e. extended stay for vacation purposes) unless these were also paid for by the entity.

J. What agencies require travel reporting?

See the list for Agencies Requiring Travel Reporting.