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Disclosure Guidance

Reminder: Any disclosure in the Disclosure and Management System must be submitted initially, renewed annually, and updated within 30 days of any changes (e.g., when payments have been received).

Overview

Outside activities and certain financial interests must be disclosed to Virginia Tech in the university’s Disclosure and Management System. There are many disclosure and COI stakeholders across the university. Please see the Contacts page for more information.

The system is designed to reduce duplicate disclosure. For example, your outside activity disclosure will cover your financial interest disclosure requirements for that entity. In these cases, the commitment aspect is assessed by your department head/supervisor and the interest aspect is assessed by the appointed university personnel. This process is automated and synchronous to the extent possible.

Investigators: Please remember that your disclosures to Virginia Tech and to federal sponsors (via the proposal being submitted by the Office of Sponsored Programs) are consistent. Please review the following guidance or contact your pre-award associate.

Disclose if:

Outside activities (i.e., consulting and outside employment) must be disclosed in the Outside Activity module. The disclosure must be approved by your department/college in advance and updated within 30 days of any changes. 

  • Note that faculty disclose financial information related to their activity in a portion of the disclosure that is viewable only by the Reserach COI Program for financial conflict of interest assessment purposes. Please remember that you must update the financial section of your outside activity disclosure within 30 days of changes (e.g., after receiving remuneration from the entity).

Approval expires on July 1 and must be received again for ongoing activities. For faculty engaged in sponsored research, continue to #2.

See the FAQs page or the Consulting and Outside Employment section of the Faculty Handbook for more information. Note that the terms for outside activities might vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).

Salaried staff must disclose additional employment outside of 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).

Contact Human Resources 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 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 certain financial interests held in the past 12 months that reasonably appear related to the Investigator’s institutional responsibilities in the Research Financial Interest module. The Research COI Program will notify you if you meet the definition of an Investigator and must disclose initially/annually, but you must independently update your disclosure within 30 days of any changes.

An Investigator might disclose all their financial interests 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.

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 disclosure is not routed for approval. It will route directly to the Research COI Program for review and development of a management plan, if needed.

See the Researcher Requirements page for more information.

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. This is an employee-initiated disclosure.

  • 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 coi@vt.edu prior to using this module.

Financial interests, as described above, must be disclosed in the Financial Interest in a Business module. The disclosure must be renewed annually and updated within 30 days of any changes (e.g., when financial interests change).

The disclosure is not routed for approval, but is instead reviewed by the Research COI Program (and Procurement in certain instances). If required, the programs will reach out to you to coordinate next steps.

See the FAQs for more information

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