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FAQs

The Disclosure and Management System is designed to support disclosure submissions across the university in accordance with multiple policies, specifically allowing:

  • Faculty to request and receive approval for participation in outside activities (i.e., consulting and outside employment);
  • Investigators on sponsored research projects to disclose financial interests, agree to management plans for financial conflicts of interest, and view active management plans for ongoing compliance; and
  • Employees to disclose when they have a financial interest in a business that is a party to a sponsored project or procurement contract/transaction. 

See the Disclosure Guidance & Requirements site for guidance pertaining to your personal circumstances.

No, as long as the university does not intend to purchase goods or services from the business.

If you engage in an outside activity (i.e., consulting and outside employment) with the business, you would disclose in the Outside Activity Disclosure Module alone. Note that the terms for outside activities vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).

If you don’t engage in an outside activity with the business (and, therefore, wouldn’t have an outside activity disclosure for the entity), you would disclose in the Research Disclosure Module alone. If the university intends to purchase goods or services from the business, you would have to disclose in the Financial Interest in a Business Disclosure Module (in addition to the relevant disclosure module described above).

Staff additional employment is disclosed in accordance with the Additional/Outside Employment Policy for Salaried Classified and University Staff (No. 4070). 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. 

Outside activities include consulting and outside employment. The terms for outside activities vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).

The Faculty Handbook makes a distinction between professional service and consulting/outside employment, and professional service might require supervisor approval depending on departmental practice and expectations of the position. Consult with your supervisor if you have questions about professional service disclosure. Please review the Faculty Handbook at 2.24 for additional guidance.

Disclosures typically require two approvals, the department head/supervisor and dean/senior administrator (only one approval is required for department heads and unit leaders). However, the exact routing procedure is determined by your department/unit. Send your disclosure to your supervisor for approval, unless otherwise instructed. Contact your department/unit with any routing questions.

Outside activities (i.e., consulting and outside employment) are disclosed 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.). Contact your supervisor and/or the policy owners/stakeholders with questions. If you have technical questions concerning the Disclosure and Management System, contact the RCOI Program at coi@vt.edu.

Proposed outside activities (i.e., consulting and outside employment) must be disclosed prior to engaging in the activity and updated within 30 days of any changes. Approval expires at the end of the fiscal year (i.e., June 30th). Disclosures must be renewed for activities that continue into the next fiscal year.

Approval of outside activities for faculty members holding nine-month appointments is not necessary during the summer provided they do not have an additional summer work assignment (e.g., summer teaching or administrative work). When the faculty member holds a 12-month appointment, university disclosure policies apply.

Faculty must disclose proposed outside activities (i.e., consulting and outside employment) in order for the department head/supervisor to make a conflict of commitment assessment. By approving a disclosure, an approver is indicating that, to the best of their knowledge, the outside activity does not represent a conflict of commitment (it will not impede upon the individual's responsibilities to the university) and is in compliance with applicable university policies (i.e., the Consulting and Outside Employment policy in the Faculty Handbook and the University Facilities Usage and Event policy [No. 5000]).

An approver is a department head or unit supervisor who assesses whether the disclosed outside activity will detract from the discloser’s time commitment and other responsibilities to the university (i.e., a conflict of commitment assessment). Note that this is not a financial conflict of interest assessment; it is an assessment of whether engaging in the activity will impede on the discloser’s time and effort commitments to Virginia Tech.

By approving a disclosure, an approver is indicating that, to the best of their knowledge, the outside activity does not represent a conflict of commitment (it will not impede upon the individual's responsibilities to the university) and is in compliance with applicable university policies (i.e., the Consulting and Outside Employment policy in the Faculty Handbook and the University Facilities Usage and Event policy [No. 5000]). The faculty member must certify that they have read and understand those policies before submitting the disclosure to you for approval. You will have the option of requiring certain conditions with your approval (e.g., requiring annual leave be taken for consulting days exceeding the maximum allowed in a given time period). 

Please note that you are assessing whether there is a conflict of commitment (COC) and not a conflict of interest (COI), the latter of which is related to financial interests. The COI determination is the responsibility of the applicable COI stakeholders who are automatically looped into the process, if necessary. As a reminder, the terms for outside activities vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).

Disclosures typically require two approvals, the department head/supervisor and dean/senior administrator (only one approval is required for department heads and unit leaders). However, the exact routing procedure is determined by your department/unit.

Send the disclosure to the RCOI Program once all approvals have been obtained, which concludes the approval routing process. 

The flag icon indicates areas for closer examination. The triangle icon indicates changes have been made to a field from a previously approved disclosure.

You will receive reminder emails until the disclosure has been fully approved in the system. You might not have completed the system action you intended. If you thought you had already requested revisions or asked for more information, please go back to the disclosure and select “Send Revisions” in order for the disclosure to be sent back to the discloser.

Disclosures should only be marked as “Not Approved” if the proposed outside activity represents an irresolvable conflict of commitment or policy violation. Consider 1) requiring the discloser to use annual leave for consulting days exceeding the maximum allowed or 2) requesting that the time commitment be reduced. You can implement these suggestions by approving with requirements or sending the discloser your requested revisions, respectively.

Financial interests are disclosed by Investigators in accordance with the Individual Conflicts of Interest and Commitment policy (No. 13010). Contact the RCOI Program at coi@vt.edu with questions.

The term “Investigator” includes the PI, project director, co-I, and any other person, regardless of title or position, with a similar level of responsibility responsible for the design, conduct, or reporting of sponsored research.

The RCOI Program will notify you if you are an Investigator and are required to disclose and take research COI training.

Investigators must disclose the following financial interests held in the past 12 months that are reasonably related to their institutional responsibilities:

  • For a single publicly traded entity, payments and equity value (determined through public prices) ˃$5,000 in total or
  • For a single non-publicly traded entity, payments ˃$5,000 or any equity interest.

Financial interests are disclosed in the context of the Investigator, their spouse, and dependent children (i.e., the Investigator's immediate family members).

  • Salary
  • Payments for services not otherwise identified as salary (e.g., consulting fees, honoraria)
  • Intellectual property payments
  • Travel reimbursements or payments on one’s behalf
  • Income from investment vehicles if you directly control the investment decisions made in these vehicles
  • Stock
  • Stock option
  • Other ownership interest
  • Payments or equity unrelated to your institutional responsibilities
  • For a publicly traded entity, payments and equity value totaling ≤$5,000
  • For a non-publicly traded entity, payments ≤$5,000
  • Income or payments from Virginia Tech or Virginia Tech Intellectual Property Foundation (VTIP)
  • Travel paid with Virginia Tech funds, including sponsored projects
  • Income from seminars, lectures, or teaching engagements; income from service on advisory committees or review panels; or reimbursed travel or travel paid on one’s behalf if it is from:
    • A U.S. federal, state, or local government agency;
    • A U.S. institution of higher education or research institute affiliated with a U.S. institution of higher education; or
    • A U.S. academic teaching hospital, medical center
  • Income from investment vehicles if you do not directly control the investment decisions made in these vehicles (e.g., mutual funds and retirement accounts)

Institutional responsibilities are defined as your professional responsibilities on behalf of Virginia Tech, which might include research, consulting, teaching, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards. The following example illustrates the process of determining the relatedness between your institutional responsibilities and a financial interest.     

Let's say you own a pizza company. Your research at Virginia Tech involves developing cancer therapeutics. A reasonable person would not suggest that your pizza company is related to your institutional responsibilities. In contrast, if your research involves consumer behaviors at buffets,  a reasonable person would think that your financial interest is related to your institutional responsibilities. 

Financial interests must be disclosed prior to engaging in sponsored research, updated within 30 days of acquiring a new financial interest, and renewed annually.

Yes. The research disclosure requires disclosure of financial interests held or received in the 12 months preceding the disclosure date.

No, as long as the university does not intend to purchase goods or services from the business. If you engage in an outside activity (i.e., consulting and/or outside employment) with the business, you would disclose in the Outside Activity Disclosure Module alone. If you don’t engage in an outside activity with the business (and, therefore, wouldn’t have an outside activity disclosure for the entity), you would disclose in the Research Disclosure Module alone. If the university intends to purchase goods or services from the business, you would have to disclose in the Financial Interest in a Business Disclosure Module (in addition to the relevant disclosure module described above).

Investigators must disclose financial interests that are reasonably related to their institutional responsibilities in order for the university to meet its obligation to review these relationships and, when necessary, develop a plan to manage, reduce, or eliminate an associated financial conflict of interest. The RCOI Program assesses and implements management strategies for financial interests disclosed by Investigators on sponsored research projects in order to promote research objectivity.

Financial interests in a business/vendor that is party to a contract/transaction are disclosed in accordance with the Individual Conflicts of Interest and Commitment policy (No. 13010). Contact the RCOI Program at coi@vt.edu with questions about sponsored project contracts or about the Disclosure and Management System. Contact Procurement with questions about procurement contracts/transactions.

Employees must disclose when they have a financial interest in a business that is a party to a sponsored project or procurement contract/transaction. An employee has a financial interest in a business 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 that is a party to the contract/transaction.

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

Financial interests in a business/vendor that is a party to a contract/transaction must be disclosed initially (before the contract is entered into) and updated within 30 days of any changes. Disclosures must be renewed annually for financial interests that continue into the next fiscal year.

No, as long as the university does not intend to purchase goods or services from the business. If you engage in an outside activity with the business (i.e, consulting and outside employment), you would disclose in the Outside Activity Disclosure Module alone. If you don’t engage in an outside activity with the business (and, therefore, wouldn’t have an outside activity disclosure for the entity), you would disclose in the Research Disclosure Module alone. If the university does intend to purchase goods or services from the business, you would have to disclose in the Financial Interest in a Business Disclosure Module (in addition to the relevant disclosure module described above).

Employees must disclose financial interests in a business/vendor that is party to a contract/transaction in order for the employee and the university to meet their state law obligations. The RCOI Program and Procurement assess financial interests related to sponsored project contracts and procurement contracts/transactions, respectively.