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The Director of the Research Conflict of Interest Program is available for consultations about COI or disclosure questions, including questions about Investigators, financial interests related to sponsored research or sponsored projects, management plans, and technical concerns involving the Disclosure and Management System.

There are many disclosure and COI stakeholders across the university. The program will forward your concern to the applicable stakeholder, as needed.

  • Faculty should contact their pre-award associate for questions about disclosing outside activities to certain federal sponsors.
  • Salaried staff must disclose additional employment outside of the Disclosure and Management System. Staff should review Policy 4070 and contact their supervisors/HR for questions about additional employment disclosure.
  • Contact Procurement at procurement@vt.edu for questions about owning or working for a company related to university purchasing.
  • Contact the Office of Export and Secure Research Compliance for questions about international entity collaborations

There are user guides for the Disclosure and Management System.

Contact coi@vt.edu with all other questions. 

Employees must disclose when they have an additional work commitment or relevant financial interest. See the Disclosure Guidance site for more information and resources, including the Disclosure Decision Tree.

Helpful tips:

  • Disclosure requirements are streamlined across types of disclosure, which means any disclosure in the university’s Disclosure and Management System is required initially, annually, and within 30 days of any changes (e.g., when financial interests change). The system is designed to be intuitive, with the landing page helping the employee decide the type of disclosure to submit, and there are user guides.
  • Additional commitment requests are “approved” (if they don’t represent an irresolvable conflict of commitment) because they are permission-seeking. Financial interests are “assessed” (whether they intersect with university business) because they are already held by the faculty member and their permissibility must be determined by the relevant university official responsible for conflict of interest determinations.
  • In some circumstances, a disclosed relationship could potentially be both a conflict of commitment and a conflict of interest. The university’s disclosure system is designed so that you don’t have to disclose the same relationship multiple times (e.g., an additional commitment disclosure will cover your financial interest disclosure requirements for that entity). In these cases, the commitment aspect is assessed by the department head/supervisor and the interest aspect is assessed by the appointed university personnel. This process is automated and synchronous.

Employees must disclose when they have an additional work commitment or relevant financial interest. See the Disclosure Guidance site for more information and resources, including the Disclosure Decision Tree.

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

The university’s disclosure system is designed so that faculty don’t have to disclose the same relationship multiple times (e.g., an additional commitment disclosure will cover the faculty member’s financial interest disclosure requirements for that entity).

If you want to 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 also disclose in the Financial Interest in a Business Disclosure Module (in addition to the relevant disclosure module described above) because it is Procurement’s only disclosure visibility. 

This website primarily addresses disclosing to Virginia Tech.

Researchers are reminded that they must agree to comply with journal disclosure policies when they submit for publication. If the RCOI Program makes a COI determination, a plan will be put in place to manage the disclosed financial interest. One of the management plans requirements will specify that the relationship must be disclosed in submissions for publication and/or presentation, consistent with journal and professional disclosure requirements and through the last written or verbal presentation of results from the project.

A researcher’s disclosures, as described in this policy and recorded in the Disclosure and Management System, do not alleviate their obligation to disclose to specific sponsors. Principal investigators, project directors, and other senior/key personnel should review the guidance on OSP’s website, which outlines the current requirements for disclosing to certain federal sponsors.

In addition to your Virginia Tech disclosures and training, some employees must also satisfy the disclosure and training requirements of the Commonwealth of Virginia. HR maintains the list of employees required to file the Statement of Economic Interests and will be in contact if this disclosure requirement applies to you.

Outside activities must be disclosed and approved in the Outside Activity Disclosure Module of the university’s Disclosure and Management System before engaging in the activity. Even in cases without compensation, advance approval is required to ensure the proposed outside activities do not constitute a conflict of commitment.

Disclosures must be renewed annually for activities that continue into the next fiscal year and must be updated within 30 days of any changes. Importantly, this means that the faculty member must update the financial interest portion of their disclosure within 30 days upon receiving remuneration from the entity.

If you disclosed your outside activity as “ongoing”, you will receive an automated notification prompting you to renew your disclosure towards the end of the fiscal year. If you will not engage in the activity/employment in the new fiscal year, no further action is necessary; your disclosure will simply expire. Those who didn’t disclose their outside activity as “ongoing” must renew their disclosure, as needed.

Outside activities include consulting and outside employment and must be disclosed. Note that the terms for outside activities might 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. 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.

The disclosure system doesn’t ask for your clients because the university requires separate disclosures for each consulting client so that conflicts of interest can be properly evaluated by designated university officials. A single disclosure denoting ownership of a consulting company with multiple unidentified clients does not allow an adequate assessment and is considered insufficient and unacceptable.

Send your disclosure to your department head/supervisor. They will be listed as your first option on the routing list.

Disclosures typically require two approvals, your 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.

The disclosure system doesn’t “know” when all approvals have been received, so sending the disclosure to the RCOI Program concludes the approval routing process.

Note that this is the only type of disclosure that receives an approval. The commitment aspect is assessed by your department head/supervisor and the financial interest aspect (if applicable) is assessed by the appointed university personnel in an automated, synchronous process.

Your department head/supervisor is making a conflict of commitment (COC) assessment (i.e., an overcommitment to multiple employers or entities). The Consulting and Outside Employment policy in the Faculty Handbook provides assessment and approval parameters.

By approving a disclosure, an approver is indicating that, to the best of their knowledge, the outside activity does not represent a COC and the activity follows guidelines in the Consulting and Outside Employment policy in the Faculty Handbook and the University Facilities Usage and Event policy (No. 5000). You will be required to certify that you have read and understand those policies before submitting the disclosure for approval.

Policy 5000 allows faculty to use university facilities if they pay the rate determined by the Controller's Office and the use is approved by their department/college in the context of their outside activity disclosure, which documents the use of university resources. This only applies in the context of approved consulting activities, and the proposed use cannot interfere with or have priority over anticipated university use of the equipment or facilities.

Contact the RCOI Program with questions about disclosing and the Disclosure and Management System, including question about whether an additional work commitment is an “outside activity” or “professional service”. There are user guides for the Disclosure and Management System.

If there is ambiguity about whether something is professional service after reading the Consulting and Outside Employment policy of the Faculty Handbook, you should consult with your department head/supervisor.

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 outside activity disclosure policies apply.

As a department head/supervisor, you will be the approver of faculty outside activity disclosures. If you are unfamiliar with your role as an approver, contact the RCOI Program.

Disclosures can be manually routed to anyone at the university, so the likely answer is you were sent the disclosure directly from the faculty member seeking approval to engage with an outside entity.

You are indicating that, to the best of your knowledge, the outside activity does not represent a conflict of commitment, it follows applicable university policies, and you can monitor it appropriately.

Specifically, that means you are indicating that it will not impede upon the individual's responsibilities to the university and the activity follows guidelines in the Consulting and Outside Employment policy in the Faculty Handbook and the University Facilities Usage and Event policy (No. 5000). The faculty member will be required to certify that they have read and understand those policies before submitting the disclosure for approval. While reviewing outside activity disclosures, the approver must consider how they will monitor the engagement.

Policy 5000 allows faculty to use university facilities if they pay the rate determined by the Controller's Office and the use is approved by their department/college in the context of their outside activity disclosure, which documents the use of university resources. This only applies in the context of approved consulting activities, and the proposed use cannot interfere with or have priority over anticipated university use of the equipment or facilities.

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.

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.

The disclosure system doesn’t “know” when all approvals have been received, so sending the disclosure to the RCOI Program concludes the approval routing process. 

Approvers do not have to contact anyone about the responses given in a disclosure unless they need assistance in making their COC assessment, as described above (“What does it mean when I “approve” a disclosure?”).

The disclosure process automatically loops in relevant stakeholders when dictated by the circumstances (e.g., the Research Conflict of Interest Program, Office of Export and Secure Research Compliance) and they will reach out promptly if next steps are necessary.

There are user guides for the Disclosure and Management System.

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 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.

You will receive reminder emails until the disclosure has been fully approved in the system. 

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.

There are user guides for the Disclosure and Management System.

Please use 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 (in certain limited circumstances) must disclose additional employment outside of the Disclosure and Management System.

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.

This question is under development. When completed, the Researcher Requirements page will be dedicated to this question.

The term “Investigator” applies to employees engaged in sponsored research with the level of responsibility similar or equivalent to a principal investigator. 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 for this purpose, but you must independently update your disclosure within 30 days of any changes (e.g., when financial interests change).

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 in the past 12 months that reasonably appear related to the Investigator’s institutional responsibilities.

The disclosure context includes the Investigator, their spouse, and their dependent children (i.e., the Investigator's “immediate family members”).

An Investigator might disclose all their financial interests (as described above) in the context of their additional work commitment disclosures. In those cases, the Investigator will be prompted to annually certify there are no changes (because the university’s disclosure system is designed so that you don’t have to disclose the same relationship multiple times). 

Payments include the following remuneration (except as exempted below) from entities other than Virginia Tech:

  • 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

Equity includes any ownership interest, including stock and stock options.

  • 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)

Don’t worry about keeping up with day-to-day changes in the value of publicly traded stock – the annual disclosure requirement is sufficient for updating previously disclosed equity interest.

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 your research at Virginia Tech involves developing cancer therapeutics. You also own a pizza company. 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 could conclude that your financial interest is related to your institutional responsibilities.

Investigators must disclose financial interests held by themselves and any member of their immediate family annually and within 30 days of any changes. Importantly, this means that the faculty member must update their disclosure within 30 days if their financial interests change.

An Investigator might disclose all their financial interests (as described above) in the context of their additional work commitment disclosures. In those cases, the Investigator will be prompted to annually certify there are no changes.

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

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

The university’s disclosure system is designed so that faculty don’t have to disclose the same relationship multiple times (e.g., an additional commitment disclosure will cover the faculty member’s financial interest disclosure requirements for that entity).

If you want to 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 also disclose in the Financial Interest in a Business Disclosure Module (in addition to the relevant disclosure module described above) because it is Procurement’s only disclosure visibility. 

Contact the RCOI Program. There are user guides for the Disclosure and Management System.

You must disclose to Virginia Tech when you or an immediate family member have a financial interest related to research or other Virginia Tech operations. This primary occurs in the context of sponsored projects and/or purchases of goods or services from the company.

An employee has a financial interest in Virginia Tech operations when they or an immediate family member (i.e., spouse or dependent children) own >3% or receive >$5,000 in payments from a business or vendor that is a party to a contract or transaction with the university. This is an employee-initiated disclosure in the Financial Interest in a Business Disclosure Module

If you have already disclosed this relationship in another module of the university’s disclosure system, you do not have to disclose it again unless there will be a purchase of goods or services from the entity. We recommend contacting coi@vt.edu for a reportability assessment.

These financial interests, as described above, must be disclosed initially (before the contract is entered into) and updated within 30 days of any changes (e.g., when financial interests change). Disclosures must be renewed annually for financial interests that continue into the next fiscal year.

The disclosure is not routed for approval, but is instead reviewed by the RCOI Program and Procurement for sponsored project contracts and purchasing contracts/transactions, respectively. If required, the programs will reach out to you to coordinate next steps.