Conflicts of Interest and Commitment
Virginia Tech recognizes the value and necessity of engaging with outside entities to translate research into beneficial products. Transparency and appropriate oversight of these relationships promotes and safeguards the interests and reputation of Virginia Tech and its employees.
Conflicts of interest and commitment are separate topics often with much overlap. Having a financial interest related to research or other Virginia Tech operations requires a financial conflict of interest (FCOI) assessment, or a determination of whether there is a risk that the financial interest could lead to bias. This determination is the responsibility of the appointed university official or designee (e.g., the Research Conflict of Interest Program).
The financial interest might stem from consulting or outside employment (i.e., 'outside activities'). Participation in outside activities requires a conflict of commitment (COC) assessment, or a determination of whether the activity would overcommit the employee to multiple employers or entities due to the potential for conflicting commitments of time and effort. The COC determination is the responsibility of the employee’s department head/supervisor.
Employees must disclose outside activities and certain financial interests in the university’s Disclosure and Management System. See the Disclosure Guidance page for more information and resources, including the Disclosure Decision Tree. Please note that the Office of Sponsored Programs maintains internal procedures related to organizational conflicts of interest (a term related to impartiality in federal contracting).
Disclosure to Virginia Tech - Overview
Employees must disclose outside activities and certain financial interests, as described on the Disclosure Guidance page. This website is a centralized resource for outside activity and financial interest disclosure to Virginia Tech.
It's important to note that a disclosed relationship could potentially be both a COC and an FCOI. The university’s disclosure system is designed to reduce duplicate disclosure and to synchronize review processes. 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.
Disclosure requirements are streamlined across types of disclosure, which means any disclosure in the university’s Disclosure and Management System is
- Submitted initially
- Renewed annually, and
- Updated within 30 days of any changes (e.g., when financial interests change).
The system is designed to be intuitive, with the landing page helping you decide the type of disclosure to submit, and there are user guides for disclosers and approvers of faculty outside activity disclosures. For approvers, see the Approving a Faculty Outside Activity Disclosure FAQ section for more information.
Virginia Tech’s Research Conflict of Interest Program has streamlined many processes for you. See the COI/COC Requirements for Researchers for more info.
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 the Office of Sponsored Programs). If you have questions about what should be disclosed via the proposal to the sponsor, please review the guidance on the Office of Sponsored Program’s website or contact firstname.lastname@example.org.
Disclosure to the Commonwealth of Virginia
In addition to your Virginia Tech disclosures, some employees must also satisfy the disclosure and training requirements of the Commonwealth of Virginia. Disclosure to the Commonwealth (i.e., filing the Statement of Economic Interests, or SOEI) is required by Virginia Tech employees when they are designated by Human Resources as being in a position of trust or have an approved exception for a financial interest related to research or other Virginia Tech operations.
Human Resources maintains the list of employees required to file the SOEI and will be in contact if this disclosure requirement applies to you. Please see the following website for more information (note that the Research Conflict of Interest Program is the point of contact for approved financial interest exceptions).
- Policy 13010, Conflict of Interest
- Faculty: Chapter 2 of the Faculty Handbook, the sections for consulting activities and outside employment
- Staff: Policy 4070, Additional/Outside Employment Policy for Salaried Classified and University Staff
- Graduate students (those holding assistantships): Graduate Catalog's Additional Employment for Students Holding a Graduate Assistantship policy
- Virginia Tech's Statement of Business Conduct Standards
- Conflicts of interest in purchasing: Procurement department's Conflict of Interest site
- Employees who must disclose to the state: HR's Statement of Economic Interests site
- Foreign Influence in Federally Sponsored Research – Guidance