Travel Disclosure Procedures & Guidance

Conflicts of Interest Review Committee
Effective: August 24, 2012
Last Revised: September 28, 2023

Washington University has developed the following procedures and guidelines regarding the requirements to disclose travel by individuals involved in the design, conduct, or reporting of research funded by an agency that follows Public Health Services’ (PHS) travel disclosure requirements stipulated in regulations governing financial conflicts of interest (42 C.F.R. Part 50 Subpart F and 45 C.F.R. Part 94).

Travel Disclosure Procedures

1. Applicability

WashU shall require individuals who meet the definition of a covered individual and are involved in design, conduct, or reporting of research funded by an agency that follows PHS COI regulations (e.g. National Institutes of Health), Department of Energy COI regulations, or as required by research sponsors, to disclose information about certain travel activities that are related to their institutional responsibilities.

2. Disclosure Requirements

Individuals must disclose the occurrence of any reimbursed or sponsored travel that appear to be related to their institutional responsibilities and are paid for by an entity other than WashU, U.S. federal, state, or local government agencies, or other U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education.

Disclosure is required when the aggregate value of the sponsored or reimbursed travel meets or exceeds an estimated $5,000 for an entity in the previous 12 months. 
The aggregate value does not include payments for services such as speaking fees. Travel includes, for instance, registration fees, accommodations, transportation costs, and meals. Outside entities may include, but are not necessarily limited to, professional societies, foreign institutions of higher education, for-profit entities, and non-profit entities.

3. Frequency

Each trip for an entity must be disclosed once an estimated aggregate value of $5,000 is reached

4. Disclosure Process

Individuals will disclose travel using the Travel Disclosure form via the Research Management System (RMS), and will not use the annual Financial Disclosure Statement. Download the Travel Disclosure Entry Quick Guide to learn more about completing the travel disclosure in RMS.

The individual shall disclose:

  • Entity that paid for the travel
  • Purpose of the trip
  • Destination
  • Duration of the trip
  • Travel paid for the individual’s spouse and/or dependent child(ren) by the entity

In order to remind individuals to disclose, an email will be sent on a monthly basis prompting the individual to disclose travel.

5. Review

Review of travel disclosure forms will be handled in accordance with the Procedures for Determining and Managing FCOIs.

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.

Prior revisions: 9/28/23, 5/25/22, 2/17/17, 8/24/12