Disclosure and Reporting External Activities
External Activities that Require Advance Approval
External Activities that Generally Require Disclosure Because of Potential Financial Conflicts of Interest
External Activities that Generally Do Not Require Disclosure
Who Should Disclose?
Any university employee (or employed student) with a financial or managerial interest (such as income, royalties, consulting, equity ownership, or service as member of the board of directors or company officer) in an external entity must disclose that interest when it meets certain defined thresholds. The requirement for disclosure also applies to such interests of the employee’s immediate family members.
All investigators with a significant financial interest (SFI) must disclose those interests that are reasonably related to their institutional responsibilities. “Investigator” means the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research.
- Collaborators, consultants, or subcontractors are considered investigators for the purposes of this policy, as is anyone identified as key personnel in the proposal or award (disclosure for non-Virginia Tech employees may be certified as compliant with COI procedures at their home institutions).
- Postdoctoral associates, graduate students, and undergraduates who meet the definition above are considered investigators.
- Investigator disclosures must include the financial interests of their spouse and dependents.
What Constitutes a Significant Financial Interest?
The definition for “significant financial interest” below applies to all investigators involved in sponsored research, regardless of the source of funds for that research.
“Significant Financial Interest”: A financial interest consisting of one or more of the following interests of the investigator (and those of the investigator’s spouse and dependent children) that reasonably appears to be related to the investigator’s institutional responsibilities:
- With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of the equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value.
- With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the 12 months preceding the disclosure, when aggregated, exceeds $5,000, or when the investigator (or the investigator’s spouse or dependent children) holds ANY equity interest (e.g., stock, stock option, or other ownership interest); or
- Intellectual property rights and interest (e.g. patents, copyrights), upon receipt of income related to such rights and interest.
A significant financial interest does NOT include the following types of financial interests:
- salary, royalties, or remuneration paid by Virginia Tech to the investigator, including intellectual property rights assigned to the institution and agreements to share in royalties related to such rights;
- income from investment vehicles, such as mutual funds and retirement accounts, as long as the investigator does not directly control the investment decisions made in these vehicles;
- income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, and institutions of higher education; or
- income from service on advisory committees or review panels for a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.
What Constitutes a Personal Financial Interest for Those Employees NOT Involved in Sponsored Research?
“Personal Interest” as defined by the Virginia State and Local Governments Conflict of Interests Act: A financial benefit or liability accruing to an officer or employee or to a member of his immediate family. Such interest shall exist by reason of (i) ownership in a business if the ownership interest exceeds three percent of the total equity of the business; (ii) annual income that exceeds, or may reasonably be anticipated to exceed, $5,000 from ownership in real or personal property or a business; (iii) salary, other compensation, fringe benefits, or benefits from the use of property, or any combination thereof, paid or provided by a business or governmental agency that exceeds, or may reasonably be anticipated to exceed, $5,000 annually; (iv) ownership of real or personal property if the interest exceeds $5,000 in value and excluding ownership in a business, income, or salary, other compensation, fringe benefits or benefits from the use of property; (v) personal liability incurred or assumed on behalf of a business if the liability exceeds three percent of the asset value of the business; or (vi) an option for ownership of a business or real or personal property if the ownership interest will consist of (i) or (iv) above.
When to Disclose
- At time of Application: Each Investigator, including subrecipient Investigators, if applicable, planning to participate in sponsored research must have an approved disclosure on file at the time of application.
- Annually: Each Investigator, including subrecipient Investigators, if applicable, must submit an updated disclosure of SFI at least annually during the period of the award.
- Renewal Application: A renewal application must be filed annually for those approved activities that extend beyond one year.
Your Personal Situation May Change
A newly acquired significant financial interest, such as might occur through marriage, inheritance, or establishment of a new company, must be disclosed within 30 days.
Links to Related Disclosure and Reporting Forms
- Disclose online through the Disclosure System
- Management Plan, Conflicts of Interest / Commitment
- Research Agreement for Students and Postdoctoral Associates
Virginia Statement of Economic Interests
A Statement of Economic Interest is required by state law, pursuant to §2.2-3114 of the Code of Virginia and Executive Order 16 (2006), of all "persons occupying such offices or positions of trust or employment in state government....as may be designated by the Governor." The Governor, by executive order, has designated those employees "who have substantial responsibility for procurement, audit, investment or other activities that could be subject to abuse or improper influence as a result of personal economic interest." The university is required to identify the relevant employees. Typically this includes senior administrators and employees (or their family members) who own a company wishing to do business with the university.
Travel Disclosures for PHS Investigators:
For faculty members with PHS/NIH funding, reimbursed or sponsored travel paid for by an external entity must also be disclosed. Disclosure includes, at a minimum, the following:
- the purpose of the trip
- the identity of the sponsor or organizer
- the destination
- the duration of the trip
Disclosure is not required for travel reimbursed by the university from any source of university funds (e.g., departmental, foundation, sponsored project), or travel paid for (or reimbursed) by a federal, state, or local government agency, an institution of higher education, affiliated research institute, or academic teaching hospital. Special rules concerning reporting of travel apply to those employees who must complete the annual Commonwealth Statement of Economic Interest form.
To disclose travel paid by an external entity or to certify that you have not received any 3rd party reimbursements within the last 12 months go to https://secure.research.vt.edu/rcr/ and select "Your Travel Disclosures".