To protect against the potential risks involved with financial conflicts of interest in research and to comply with federal regulations, Saint Louis University has developed a policy on financial conflict of interest in research.
The University believes that establishing clear guidelines and principles for disclosing and managing financial conflicts of interest ensure that the highest level of integrity is maintained in SLU's research endeavors. The existence of a financial conflict of interest does not indicate wrong doing on the part of the investigator; however, if a conflict exists, it must be reduced, managed, or eliminated.
Submitting an Outside Interest Disclosure (OID)
The Outside Interest Disclosure (OID) form is the sole mechanism for disclosing outside financial relationships for review. The OID is accessible through InfoEd. Read and download a step-by-step guide on completing the OID.
Training on the financial conflict of interest in research policy is required, and a link to the training presentation is included in the InfoEd disclosure.
If you do not submit your OIDwithin 30 days of the disclosure request, you will no longer have access to other eRS system areas until the disclosure has been submitted.
Any investigator who has applied for or engaged in externally-funded research who does not submit an OID or who does not comply with the Financial Conflict of Interest in Research policy will be referred to the associate vice president for research for corrective action.
For any more information regarding the Financial Conflict of Interest in Research policy, email COI@slu.edu or call 314-977-7047.
Frequently Asked Questions
A financial conflict of interest in research refers to a situation in which a significant financial interest of an investigator could directly and significantly affect the design, conduct, or reporting of the investigator's research or research-related educational activities.
All individuals responsible for the design, conduct, or reporting of externally-sponsored research. This includes:
- All SLU faculty, staff, students and other individuals (regardless of pay) who will
be responsible for the design, conduct or reporting of the project must complete an
- All individuals listed as senior/key in the application must complete an OID.
- All individuals listed on the IRB research team must complete an OID.
- Undergraduate students are generally not required to complete an OID unless there is an expectation that they could significantly influence the design, conduct or reporting of the project or are listed on the IRB research team.
Non-SLU personnel paid by sub-award:
- All non-SLU senior/key personnel (regardless of pay) listed on an application and/or award for external research funding.
- Their home institution can cover their COI review (see below).
Non-SLU personnel not covered by sub-award:
- All other non-SLU individuals responsible for the design, conduct or reporting of
research. The SLU PI makes this determination.
- If a non-SLU collaborator is listed as senior/key in the grant application, he/she must complete a non-SLU COI disclosure prior to the submission of the grant application.
All investigators responsible for the design, conduct, or reporting of research at Saint Louis University must submit an annual Outside Interest Disclosure (OID) form, whether or not the individual believes a conflict of interest exists. See below for a brief description of what types of financial interests must be disclosed. If review of the disclosure identifies a conflict that needs to be managed, the investigator will be contacted for further information and instruction.
Investigators must disclose financial interests that reasonably appear related to
their institutional responsibilities and/or sponsored projects. This includes financial
interests of the investigator, their spouse, and their dependent children.
Examples of financial interests that must be disclosed include (but are not limited to):
- Payments for services (consulting fees, speaking honoraria)
- Advisory board
- Spouse’s employment (if related to the investigator’s institutional responsibilities or sponsored projects)
- Publication royalties
- Income from serving as an expert witness
- Income from serving as a board member
- Equity, both public (stock) and private (startup company)
- License fees or royalties from intellectual property
- Income from foreign universities or foreign governments
- Sponsored travel (see question below for additional information)
Examples of financial interests that do not need to be disclosed:
- SLU salary
- Income or travel from service on advisory committees or review panels, seminars, lectures,
or teaching engagements if the activity is sponsored by a federal state, or local
government agency, an Institution of higher education as defined at 20 U.S.C. § 1001(a),
an academic teaching hospital, a medical center, or a research institute that is affiliated
with an Institution of higher education
If you have a question about whether a financial interest needs to be reported, we generally recommend disclosure. You can also contact firstname.lastname@example.org if you have any questions about a situation or financial interest.
If you have a financial interest that is potentially related to your SLU research, your OID and research will be reviewed by the Saint Louis University Conflict of Interest in Research Committee (COIRC). The COIRC meets monthly. The committee determines whether the situation creates a conflict of interest, and if so, decides on appropriate management plans for individual cases. Appropriate management plans ensure the reduction, management or elimination of the conflict.
The conflict of interest training module is different from the CITI training for human subjects. You must watch the conflict of interest training video linked in the InfoEd system if you are involved in research.
In order to comply with federal regulations for conflict of interest, all non-SLU
personnel must assure compliance with the SLU FCOIR policy prior to the submission
of any external application for research funding and before award funds are disbursed.
If a non-SLU researcher will be part of a subaward agreement, then the subcontracting organization can provide written documentation indicating its intent to use its own policy. Satisfactory documentation includes one of the following:
- Letter of Intent to Establish a Consortium Agreement (SLU as main)
- COI Certification Template Letter
If a non-SLU researcher is involved on the project without the issuance of a subaward, or if a subcontractor elects to comply with SLU's FCOIR policy, then a non-SLU COI disclosure form is required from each non-SLU investigator involved in the design, conduct, or reporting of the research. The non-SLU disclosure must be submitted to SLU prior to the submission of any external application for research funding. FCOI training will also be required at the time of award, and the non-SLU disclosure must be updated at least annually or when changes occur.
Any non-SLU investigator who is listed as a senior/key person on a grant application will need to submit the non-SLU disclosure prior to the submission of the grant application.
If the non-SLU collaborator individual will not be involved in the design, conduct, or reporting of the project and will not be committing effort, they can be listed in the senior/key person section with a role of “other” and a description of “other significant contributor.” Additional information can be found here or contact email@example.com.
Yes. If you have taken a trip that was paid for directly or reimbursed to you by an external entity, you must complete a travel disclosure in InfoEd within 30 days of the trip. Click here for instructions for the travel disclosure.
Examples of travel you must report:
- Trips paid by professional societies
- Reimbursed or paid conference fees
- Trips paid by foreign universities/foreign governments
- Travel paid directly by a research sponsor
Examples of travel you do not need to report:
- Trips paid by your department
- Trips paid by a grant (e.g., trips booked in Concur)
- Trips paid by another university or medical center in the U.S.
- Trips paid by a U.S. federal, state or local government agency (e.g., NIH study section)
Contact firstname.lastname@example.org or 314-977-7047 if you have any questions about travel.