Questions and Answers

The activities listed below are among those governed by federal and state laws and regulations. The website references will give you more information about these requirements, and how Washington University in St. Louis complies with them.

Managers and supervisors are responsible for complying with federal and state laws and regulations affecting their areas of responsibility and for ensuring that members of the university community under their direction do so as well. Managers and supervisors are responsible for determining the appropriate level of knowledge that each university community member under their direction needs in order to do his/her work correctly and compliantly, and for ensuring they receive the appropriate information and training. To help achieve compliance and obtain appropriate information and training, managers and supervisors should access the relevant Washington University policies and information on the corresponding websites indicated, as well as request advice and assistance as needed from the pertinent university personnel and area-specific compliance offices described throughout the rest of this answer to Question 1. If in doubt of whom to contact, contact the University Compliance Office at 362-4915 for assistance in making that determination.

Examples of areas of university activity governed by federal and state laws and regulations:

 

Computer use & security policies
Washington University strives for balance between its desire to promote and enhance the free exchange of ideas and its need for security of critical information and systems. Washington University’s guidelines call for respectful and responsible use of its computer networks to protect the rights of individuals and to warn against actions that may violate the law, such as the use of copyrighted, deceptive, defamatory or obscene materials. The guidelines also state how critical security is to the university’s physical network, computer operating systems and application programs. Members of the university community are required to follow these guidelines. Additional information can be obtained from Kevin Hardcastle, Chief Information Security Officer at 314-935-7986.

Confidentiality
Washington University maintains confidential records for a variety of business needs. Records include detailed information about patients receiving treatment, students, job applicants, employees, finances and future planning. Many records such as medical records and student records must be kept confidential as a matter of federal law.Members of the university community are expected to protect this information by safeguarding it when in use, storing it properly when not in use, and discussing it only with those who have a legitimate business need to know. Community members who are uncertain about the use of university records and information should contact their supervisors.

Conflict of interest policies
The university and its community members are responsible for guarding against conflicts of interest that might compromise the integrity and objectivity of the university community. The university as a whole, and the School of Medicine, both have conflict of interest policies.Community members should familiarize themselves with these policies and disclose conflicts of interest as required by the policies. Additional information may be obtained from the following:

Environmental health and safety
Washington University must comply with government rules and regulations that protect the environment and promote workplace safety. The university must operate its facilities with all of the necessary permits, approvals and controls, especially with respect to handling and disposal of hazardous and regulated materials and waste. Anyone working with or around these materials must be familiar with the rules, regulations and policies that apply to them. Additional information may be obtained by contacting the Environmental Health and Safety Office at 314-362-6816.

Export Control
Washington University has a policy of open research that promotes academic freedom and the free exchange of ideas. Many international students, postdocs, and scholars work on campus, and international collaborations continue to grow. The University is also committed to compliance with federal laws that govern the transfer of controlled technology and information to foreign countries and to foreign nationals within the U.S., including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) (collectively, “Export Control Laws”). Members of the University community must understand how Export Control Laws apply to their research, how to comply, and when to seek assistance. Export control support is available from the Export Control Manager at (314) 747-1378 or OVCRExportCompliance@wustl.edu.
For more information visit: Export Control

Foreign Corrupt Practices Act
The Foreign Corrupt Practices Act (FCPA) imposes certain restrictions on international transactions and activities.  Of particular note is its broad prohibition on improper payments to foreign government officials, a category that includes employees of many foreign universities.  The University’s Office of the Vice Chancellor and General Counsel provides training sessions to school leaders and CFU department personnel who may be involved with international activities.  For training needs, contact the Assistant Vice Chancellor & Associate General Counsel at (314)362-9071.  For questions regarding international transactions and compliance with Foreign Corrupt Practices Act provisions, contact the Associate Vice Chancellor for Finance & Controller at (314)935-9853.  The University’s international policies and resources can be found at https://global.wustl.edu/international-policies-resources/

HIPAA (Health Insurance Portability and Accountability Act) 
Privacy and SecurityWashington University is committed to conducting business in compliance with national standards for privacy, security and electronic transactions of Protected Health Information. Members of the university community are expected to follow the university’s HIPAA policies and procedures. Additional information can be obtained from the HIPAA Privacy Office at 314-747-0865 or hipaa@wustl.edu or from the Information Security Office at 314-935-7986.

Human resources-related matters including equal employment, harassment, etc.  (Employee Handbook)
Washington University is committed to a work environment free of harassment and disruptive behavior, and to providing an equal opportunity work environment where every member of the university community is treated with fairness, dignity and respect. No one shall discriminate against any individual on the grounds of race, color, religion, sex, age, disability, sexual orientation, national origin or any other factor prohibited by law.All members of the university community, especially supervisors, must be familiar with laws, regulations and policies related to employment matters. Some of the relevant university policies on employment matters include:

Minors at WU or participating in WU programs/Reporting suspected child abuse, neglect or inappropriate interactions with minors
The purpose of these policies regarding minors is to: 1) provide for appropriate supervision of minors (children under the age of 18) participating in activities and programs taking place on Washington University property, in University owned or managed facilities, and under the exclusive authority and direction of the University in other locations, and 2) require immediate reporting of any instances or suspected instances of child abuse or inappropriate interactions with minors to law enforcement and to the University’s Human Resources Office. If you see or suspect something that you think may be inappropriate, immediately contact one of the following:

  • Washington University Police Department (314-935-5514)
  • Washington University School of Medicine Protective Services Department (314-362-4357)
  • Vice Chancellor for Human Resources (314-935-7746)
  • Washington University Compliance Hotline (314-362-4998)-reports can be made anonymously.

By virtue of your job/role, you may also have a responsibility to notify the Missouri Child Abuse and Neglect Hotline at 1-800-392-3738. For a complete list of individuals with that responsibility, see http://www.moga.mo.gov/mostatutes/stathtml/21000001151.HTML.  Minors at Washington University or Participating in Washington University Programs and Requirements regarding Reporting Suspected Child Abuse, Neglect and Inappropriate interactions with Minors

Research

Physician and professional medical billing and medical record documentation (opbc.wustl.edu)
The university has a policy on Compliance with Physician Billing Regulations and a Physician Billing Compliance Office. All faculty and staff who have any involvement in the documentation, coding and/or billing of professional medical services must be familiar with this policy and its related regulations (including the Federal False Claims Act). Compliance support is available from the Physician Billing Compliance Office at 314-747-7661.
Physician Billing Compliance Manual
False Claims Laws for Federal and State Health Care Programs

Research integrity
In the course of their work, community members engaged in research may encounter situations that raise questions about the integrity of research practices, assemblage of data and/or publication of such data. The Research Integrity Policy addresses the procedures for allegations of misconduct in research, which is defined as fabrication, falsification or plagiarism in proposing, conducting or reviewing research or in reporting results. Misconduct in research also includes violations of federal and institutional rules and regulations governing the conduct of research involving human subjects.  Additional information may be obtained from the Vice Chancellor for Research at 314-747-0515.

Sponsored research grants and contracts
Washington University receives grants and contracts from federal and non-federal sources. Faculty and staff who are involved in federally sponsored research must follow federal rules and regulations related to that work. Failure to observe government rules and regulations can result in the loss of funds from grants and contracts, and, in some instances, civil fines and criminal penalties. With respect to grants and contracts from non-federal sources, the university expects compliance with their requirements. Compliance support is available from the Associate Vice Chancellor for Research Administration at 314-747-6253 or the Associate Vice Chancellor for Finance & Sponsored Projects at 314-935-7089. For more information, visit: Office of Sponsored Research Services or Sponsored Projects Accounting

University documents and record retention
Every member of the university community is responsible, within the scope of his/her own work, for the integrity and accuracy of the university’s documents and records. No one may falsify or improperly alter information on any record or document. University documents and records are retained in accordance with the law and the university’s record retention policies.  Additional assistance is available from the university’s Accounting Department, 314-935-4562, and the Physician Billing Compliance Office, 314-747-7661. For more information, visit: University Retention Policies

Workplace health and safety
Washington University seeks a healthy and safe environment for all members of the university community and for visitors. Every community member is obligated to perform his/her job in a safe manner and to follow all safety rules and procedures. Community members should immediately report any hazardous conditions or job-related illness or injury to their supervisors. Assistance regarding workplace safety is available from the Environmental Health and Safety Office at 314-362-6816.

 

The first paragraph of the Statement of General Principles answers this question; for example, faculty, staff, alumni, volunteers, members of the Board of Trustees and its committees.

Students are not subject to this code of conduct unless they are employed by the university or represent it. Several schools have policies that pertain to student behavior. Deans’ offices are the best source of information about these policies. Students may be covered by other university policies depending on their circumstances.

A code of conduct is a restatement of the guidelines we believe members of the university community are already following. Many activities within the university have de facto codes of conduct, even though they might not be called by this name; the university’s policies concerning research integrity and conflict of interest are two examples.

The university code of conduct complements and reinforces these existing statements. It does not replace them. Many other organizations and universities have codes of conduct. Finally, the federal government expects organizations that are subject to its laws and regulations, and that receive federal funding, to have written codes of conduct.

Your daily work should not be changed. You should already be following the principles in the code of conduct.
All current members of the university community have received or will receive a copy of the code of conduct. New faculty and staff will receive the code of conduct during their orientation process. A summary of the code of conduct will be published annually in the Washington University Record.

In general, no. Even if you are confident that your decisions or recommendations are not influenced by gifts or favors from vendors, the appearance of influence can be as important as its reality. Financial gifts or favors are never permitted. Gifts or favors in kind may be accepted if their value is incidental. Additional information regarding procurement issues may be obtained from the Assistant Vice Chancellor of Resource Management at 314-935-5727.

For more information, visit: Procurement Conflict of Interest Policy

All faculty with Instructor or above appointments complete conflict of interest disclosures annually.  Other faculty members and staff members should report potential or actual conflicts of interest to their immediate supervisors.  Supervisors decide whether a conflict of interest exists. Refer to the university’s Conflict of Interest policy.

No, as long as you sincerely believe a violation may have occurred. If you aren’t sure whether a violation has occurred, you can discuss your concerns with any of the individuals listed on the Procedures for Reporting Violations or Concerns page.

No. Any such directions by a supervisor are not authorized by the university. The university encourages you to report any violations of which you are aware. Washington University does not tolerate retaliation and takes disciplinary action if retaliation occurs.

Yes. A telephone contact has been established in the university Compliance Office, 314-362-4998. All incoming calls are anonymous, unless the caller wishes to leave identifying information to help facilitate follow-up. This telephone line does not have caller ID or any indication of where the call is coming from. In addition, other existing contacts for specific activities are listed in the code of conduct. You may request anonymity when calling them. You may also use the Online Reporting Form to report violations or concerns.

It depends on the severity of the violation, the certainty you have about the violation and your position of responsibility. A final decision would be based on the individual facts and circumstances of each case. Obviously, the university is not well served if violations are not brought to the attention of those in a position to address them.

The University Compliance Office, the Office of the Vice Chancellor and General Counsel or other offices will investigate potential violations to the extent they have the expertise to do so. Others with specific expertise will become involved as appropriate and necessary.

The decision will be made in consultation with the Office of the Vice Chancellor and General Counsel, the Office of Human Resources on the appropriate campus, the university Compliance Office and other individuals and offices as appropriate.

Your involvement depends on the complexity of the issue reported. The more information you are able to provide, the easier the matter will be to investigate. Once you report a violation, your future involvement would likely be limited to follow-up questions from the University Compliance Office or other offices.

All violation reports and the results of the subsequent investigations will be held in confidence and will be disclosed only on a need-to-know basis. In some instances the reporting party may receive feedback following the completion of the investigation. During the investigation, the university will protect the privacy of both the persons who report violations as well as those individuals against whom allegations are made.