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Disclosure Guidelines & Requirements

Overview

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There are 3 circumstances that require employees to disclose to Virginia Tech in the Disclosure and Management System, which is used for disclosure submissions across the university in accordance with multiple policies. If the following disclosure criteria apply, the employee must submit a disclosure in the corresponding disclosure system module. 

Faculty must disclose proposed involvement in outside activities (i.e., consulting and outside employment) in order for their supervisor to make a conflict of commitment determination. This is a faculty-initiated disclosure.

Staff and graduate students (in certain limited circumstances) must disclose additional employment outside of the Disclosure and Management System.

  • For more information, see the “Additional Work Commitment Disclosure” guidance below.

For employees engaged in sponsored research with the level of responsibility similar or equivalent to a principal investigator, financial interests that reasonably appear related to the Investigator’s institutional responsibilities must be disclosed. The RCOI Program will notify you if you meet the definition of an Investigator for this purpose.

  • For more information, see the “Research Disclosure” guidance below.

An employee has a financial interest in a business/vendor when they or an immediate family member (i.e., spouse or dependent children) hold >3% of the total equity in or receive >$5,000 in annual payments from the business/vendor. This is an employee-initiated disclosure.

Those who have already disclosed a relationship in either of the above modules are not required to disclose again in this module, unless there will be a purchase of goods or services from the entity.

  • For more information, see the “Financial Interest in a Business” guidance below. 

There are many disclosure stakeholders across the university. Contact the RCOI Program with questions about 1) Investigators; 2) financial interests related to sponsored research and sponsored projects; or 3) technical issues concerning the Disclosure and Management System. For questions outside of the purview of the RCOI Program, contact the stakeholder for that area as outlined below. Your disclosures, as described above, do not alleviate your obligation to notify OSP of any disclosure requirements to individual sponsors. Visit OSP’s website for federally-sponsored research disclosure guidance.

Note: Certain employees are required to disclose to the Commonwealth of Virginia (i.e., the Statement of Economic Interests). HR will contact you if this disclosure requirement applies to you. VTCSOM faculty members who are not employed by Virginia Tech should contact their supervisor or institution of employment for disclosure requirements.

The Outside Activity Disclosure Module of the Disclosure and Management System is used for faculty to request and receive approval for participation in outside activities (i.e., consulting and outside employment) in accordance with the Consulting and Outside Employment policy in the Faculty Handbook and the Individual Conflicts of Interest and Commitment policy (No. 13010). Note that the terms for outside activities vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).

The outside activity disclosure must be approved by your department and/or college prior to engaging in the proposed outside activity and updated within 30 days of any changes. Approval expires on July 1st and must be received again for ongoing activities.

Staff must complete form P-36 in accordance with the Additional/Outside Employment Policy for Salaried Classified and University Staff (No. 4070) to request and receive permission for additional employment. Contact HR with any questions.

Graduate students on full assistantships must disclose additional employment to Virginia Tech in the manner prescribed in the Additional Employment for Students Holding a Graduate Assistantship policy of the Graduate Catalog. Contact the Graduate School with any questions. There are no additional employment disclosure requirements for graduate students who are not on full assistantships or for undergraduate student employees.

Investigators must disclose financial interests held in the past 12 months that are reasonably related to their institutional responsibilities in accordance with the Individual Conflicts of Interest and Commitment policy (No. 13010). Investigators must disclose when they or an immediate family member:

  • Receive/hold >$5,000 in payments and equity value (determined through public prices) in total for a publicly traded entity or
  • Receive >$5,000 in payments or hold any equity interest in a non-publicly traded entity annually.

Financial interests are disclosed in the context of the Investigator, their spouse, and their dependent children (i.e., the Investigator's immediate family members). The term “Investigator” includes the PI, project director, co-I, and any other person with a similar level of responsibility for the design, conduct, or reporting of sponsored research. Exceptions include personnel or students whose research activities are directly supervised. The RCOI Program will notify you if you meet the definition of an Investigator.

The research disclosure must be submitted prior to engaging in sponsored research, updated within 30 days of any changes, and renewed annually. It is not routed for approval, but is reviewed by the RCOI Program in the context of awarded sponsored projects. If required, a management plan will be put into place prior to the expenditure of funds (or within 60 days when a financial conflict of interest is identified during an ongoing project). Management plan terms are formalized and accepted in the Disclosure and Management System.

Employees, who are typically referred to this module, must disclose financial interests in a business/vendor that is a party to a sponsored project or procurement contract/transaction with Virginia Tech in accordance with the Individual Conflicts of Interest and Commitment policy (No. 13010) and prior to the university entering into the contract. The disclosure must be renewed annually and updated within 30 days of any changes. The disclosure is not routed for approval, but is reviewed by the RCOI Program and Procurement, as applicable.

Those who have already disclosed a relationship in either of the above modules are not required to disclose again in this module, unless there will be a purchase of goods or services from the entity.