Frequently Asked Questions
I have a question about:
The Research Conflict of Interest Program is available for COI and COC consultations. Contact the program with your questions relating to outside activity or financial interest disclosure.
There are many disclosure and COI stakeholders across the university. The program will forward your concern to the applicable stakeholder, as needed.
- Faculty should review OSP’s website, which outlines the current requirements for disclosing to federal sponsors, and contact their firstname.lastname@example.org with questions.
- Contact Procurement at email@example.com 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
- 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.
There are user guides for the Disclosure and Management System.
Contact firstname.lastname@example.org with all other questions.
The university’s disclosure system is designed to reduce duplicate disclosure to the extent possible. For example, a faculty member’s outside activity disclosure will cover their financial interest disclosure requirements for that entity.
If you already disclosed your financial interest (exceeding 3% equity or $5,000 in payments) in a module and the financial interest is related to sponsored research contracting, you do not need to disclose again. If your financial interest relates to purchasing, real estate, or non-research sponsored projects, you must also disclose in the Financial Interest in a Business module because it is the only way to loop in the appropriate COI stakeholders. Please contact email@example.com to discuss.
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 Research COI Program makes an FCOI determination, a plan will be put in place to manage the researcher’s financial interest. One of the management plan 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.
Please remember that your disclosures, as described throughout these pages and recorded in the Disclosure and Management System, do not alleviate your obligation to disclose to federal sponsors (via the proposal being submitted by OSP). If you have questions about what should be disclosed via the proposal to the sponsor, please review the guidance on OSP’s website or contact firstname.lastname@example.org.
In addition to your Virginia Tech disclosures, 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. Please see HR’s SOEI website for more information.
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 when changes occur (e.g., after receiving remuneration from the entity).
If you marked your outside activity as ongoing in your disclosure, you will receive an automated courtesy reminder 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 whose outside activities are not ongoing must renew their disclosures independently, as needed.
Outside activities include consulting and outside employment and must be disclosed in the university’s Disclosure and Management System. Note that the terms for outside activities might vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.). Professional service, defined by the Faculty Handbook, is a separate concept and is not disclosed in the disclosure system. If there are questions about departmental practice and professional service, please review the Faculty Handbook at 2.25 for additional guidance and consult with your supervisor if you have questions.
The disclosure system doesn’t ask for your clients because the university requires separate disclosures for each consulting client. The disclosure system, designed to reduce duplicate disclosure, loops in relevant university officials so that financial conflicts of interest can be properly evaluated. A single disclosure denoting ownership of a consulting company with multiple unidentified clients does not allow an adequate assessment.
Route your disclosure to your department head/supervisor. The disclosure system will suggest your department head/supervisor as the person to whom the disclosure should be routed. You can always use the Another person field to manually enter the correct name if the suggested names aren’t current.
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 a process designed to be automated and synchronous to the greatest extent possible.
The Faculty Handbook contains specific approval criteria. In summary, approval indicates that, to the best of your approver’s knowledge, the outside activity does not represent a conflict of commitment, it follows applicable university policies, and they can monitor the activity appropriately. The university policies that employees with outside activities must follow are the Consulting and Outside Employment section in the Faculty Handbook and the University Facilities Usage and Events policy (No. 5000).
Contact the Research COI Program with questions about disclosing and the Disclosure and Management System. There are user guides for the Disclosure and Management System (for disclosers and approvers of faculty outside activity disclosures).
If there is ambiguity about whether something is professional service after reading the Consulting and Outside Employment section of the Faculty Handbook, please consult with your department head/supervisor. The Director of the Research COI Program is also available for consultations.
Approval of outside activities for faculty members holding nine-month appointments is not necessary during the summer if they don’t 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.
Disclosures can be manually routed to anyone at the university, so it is likely you received the disclosure directly from the faculty member seeking approval to engage with an outside entity.
The system suggests the discloser’s department head/supervisor as the person to whom the disclosure should be routed. The suggested person is imported from Banner’s Supervisor field. The discloser can always use the Another person field to manually enter the correct name, even if the Banner field isn’t current.
If you are not the correct approver, please contact email@example.com so that the disclosure can be rerouted.
The Faculty Handbook contains specific approval criteria. In summary, approval indicates that, to the best of your approver’s knowledge, the outside activity does not represent a conflict of commitment, it follows applicable university policies, and they can monitor the activity appropriately.
The university policies that employees with outside activities must follow are the Consulting and Outside Employment section in the Faculty Handbook and the University Facilities Usage and Events policy (No. 5000).
Faculty are required to certify that they have read and understand those policies before submitting the disclosure for approval.
Note that you are assessing whether there is a conflict of commitment (COC) and not a financial conflict of interest (FCOI). Financial conflicts of interest are related to financial information and are the responsibility of the Research COI Program professionals, who are automatically looped into the process by the disclosure system.
Disclosures typically require two approvals, the department head/supervisor and dean/senior administrator (only one approval is required for department heads and unit leaders). Routing specifics are determined by your department/unit. The system will remind you to route the disclosure to the Research COI Program once all approvals have been obtained, which concludes the approval routing process.
Only if you need assistance in making your approval assessment (as summarized above and described in the Faculty Handbook at 2.25).
The system, which is designed to reduce duplicate disclosure, automatically loops in relevant stakeholders when dictated by the circumstances (e.g., the Research COI Program). The outside activity disclosure approval process runs concurrently with these workflows.
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 shouldn’t get an email if you approved a disclosure, so 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 Back to Discloser for the disclosure to be sent back to the faculty member.
You will receive reminder emails until you complete an Approver Action in the system.
Disclosures should be marked as Not Approved if the proposed outside activity represents an irresolvable conflict of commitment or policy violation. Solutions to the exceeded time maximums include requiring the faculty member use annual leave for consulting days that exceed the maximum allowed, or requesting that the time commitment be reduced.
You can implement these suggestions by approving the disclosure with conditional requirements or sending the disclosure back to the discloser with your requested revisions, respectively.
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 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.
Certain researchers, called Investigators, have disclosure and training responsibilities. The term 'Investigator' applies to employees engaged in sponsored research with the level of responsibility similar to a principal investigator. Exceptions include personnel or students whose research activities are directly supervised.
The Research COI Program will notify you if you meet the definition of an Investigator for disclosure and training purposes, 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 annual payments and equity value (determined through public prices) in total for a publicly traded entity or receive >$5,000 in annual payments or hold any equity interest in a non-publicly traded entity. This is in the context of financial interests that reasonably appear related to the Investigator’s institutional responsibilities and were held/received in the past 12 months.
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 outside activity disclosures. In those cases, the Investigator will be prompted to annually certify there are no changes to their financial interests (because the university’s disclosure system is designed to reduce duplicate disclosure).
Payments include the following remuneration (except as exempted below) from entities other than Virginia Tech:
- 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)
No. Spousal information is analyzed by the hiring department, in coordination with the provost’s office, to determine any necessary next steps, which are fulfilled alongside your hiring.
However, it’s important to note that your spouse might be relevant to your disclosure responsibilities as a sponsored research Investigator. That is because your research financial interest disclosure includes certain financial interests held by you, your spouse, and your dependent children (i.e., your ‘immediate family members’). Therefore, the financial interests of your immediate family members might be relevant to a management plan developed for a financial conflict of interest related to a sponsored research project.
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 outside activity disclosures. In those cases, the Investigator will be prompted to annually certify there are no changes to their financial interests.
Yes. The research disclosure requires disclosure of financial interests held or received in the past 12 months preceding the disclosure date.
Unpaid affiliate faculty do not typically have outside activity disclosure requirements. However, anyone serving as a PI/co-I on sponsored research (i.e., an ‘Investigator’) must disclose certain financial interests to Virginia Tech. The Research COI 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).
No, as long as the company does not intend to contract with the university. The university’s disclosure system is designed to reduce duplicate disclosure. For example, an outside activity 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 module alone. If you are a sponsored Investigator and you don’t plan to 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 Financial Interest module alone. Finally, if your financial interest relates to purchasing, real estate, or non-research sponsored projects, you must disclose again in this Financial Interest in a Business module to loop in relevant COI stakeholders at the university. Please contact firstname.lastname@example.org to discuss further.
A sponsored research management plan documents the strategies for managing a financial conflict of interest. It uses specific strategies (a.k.a. mitigations) to promote research objectivity, including mitigations to protect the academic and professional progression of graduate students and post-docs. Examples of frequently adopted mitigations include disclosure to the study team as well as disclosure in ensuing publications and presentations. In some cases, the plan will address state law conditions that apply to the employee and/or the role of designated oversight personnel.
It is generally prohibited for an employee (or their spouse/dependent children) to have a financial interest related to university contracting when the employee holds >3% ownership in or receives >$5,000 in annual payments from a business/vendor that is party to a university contract/transaction. Possible exceptions to this prohibition might exist if steps are taken before the university contract begins, including disclosure. The Financial Interest in a Business module is for employees to disclose a financial interest related to Virginia Tech contracting (e.g., a sponsored project or purchase).
If you already disclosed your financial interest in another module and your financial interest is related to sponsored research contracting, you do not need to disclose again via this module. If your financial interest relates to purchasing, real estate, or non-research sponsored projects, you must disclose again in this module. It is recommended that you contact email@example.com prior to using this module.
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. It will route to the Research COI Program and other relevant stakeholders (as identified by the discloser). If required, the programs will reach out to you to coordinate next steps.