SBIR and STTR Guidance

Outside activities and certain financial interests must be disclosed to Virginia Tech in the Disclosure and Management System, as described on the Disclosure Guidance page. The module you use depends on your relationship with the small business applicant. After the disclosure is submitted, the Research COI Program will reach out to coordinate next steps, if any.

If you want to consult or work for the entity:

• You must use the Outside Activity module if you want to participate in an outside activity (i.e., consulting or outside employment) with the small business because it requires your department head/supervisor’s prior approval. This is a faculty-initiated disclosure that must be submitted in the Disclosure and Management System initially, renewed annually, and updated within 30 days of any changes (e.g., when financial interests change). Please note that the financial interest portion of your outside activity disclosure must be updated within 30 days when changes occur (e.g., after receiving remuneration from the entity).

If you have a financial interest in the small business that exceeds certain thresholds, you must disclose the financial interest to Virginia Tech.

• If you want to consult or work for the entity, you would disclose in the Outside Activity module as described above.
• If you’re a sponsored researcher, the Research COI Program will prompt you to submit the Research Financial Interest Disclosure initially/annually. If you've disclosed all your financial interests in the context of your outside activity disclosures, you'll be prompted to annually certify there are no changes to your financial interests. Please remember you must independently update your disclosure within 30 days of changes.  
• If your financial interest is related to university contracting, you must disclose in the Financial Interest in a Business module. 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.

_{* A financial interest held by you (or your spouse/dependent children) that a) is related to Virginia Tech contracting and b) exceeds 3% equity in or $5,000 in annual payments from the business/vendor.}

Please note that the information on this website pertains to disclosing to Virginia Tech. 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 foreigninfl@vt.edu. 

If you or any member of the study team have disclosed a financial interest in the small business issuing the subaward that exceeds certain thresholds, the Research COI Program will develop a plan for managing the FCOI. The management plan is designed to mitigate the conflict, promote research objectivity, and provide academic and professional protection of graduate students and postdoctoral scholars, respectively. The Management Plan Advisory Committee (MPAC), a standing committee of the university, will make recommendations to the program director regarding how the financial conflict of interest should be managed to ensure that sponsored research will be objective and free from bias, to the extent possible. The management plan must be adopted prior to the start of the research and will be based on state and federal requirements and input from MPAC and the Investigator with an FCOI, as needed.

• It is critical to note that financial interests related to the small business must be submitted and reviewed by the Research COI Program before the university enters into a contract with the small business. Disclosures must be updated within 30 days of any changes (e.g., when financial interests change).

The elements of the management plan will depend on the nature of the financial interest and the proposed research, but will include, at a minimum, disclosure of the financial interest to the study team, including students and post-docs, and in presentations/publications. Management plan terms are formalized and accepted in the Disclosure and Management System.