Frequently Asked Questions

Outside activities and certain financial interests must be disclosed to Virginia Tech in the university’s Disclosure and Management System. See the Disclosure Guidance page for more information and resources, including the Disclosure Decision Tree.

Maybe. 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 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 might also need to disclose in the Financial Interest in a Business module because it is the only way to loop in the appropriate conflict of interest stakeholders. Contact coi@vt.edu to discuss. 

While 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 Conflict of Interest program makes a financial conflict of interest 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.

In addition, remember that your disclosures in the Disclosure and Management System do not alleviate your obligation to disclose to federal sponsors in the proposal being submitted by OSP.  If you have questions about what should be disclosed in the proposal to the sponsor, review the guidance on OSP’s website or contact foreigninfl@vt.edu.

Finally, 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 (SOEI) and will be in contact if this disclosure requirement applies to you. See Human Resource’s SOEI website for more information.

Consulting and outside employment during your appointment term is typically allowable up to one day per week. With supervisor approval, additional days may be charged to annual leave. Note that release time from university work is not typically available for activities that are primarily personal in nature, do not enhance the faculty member’s professional skills, or are not a potential benefit to the university. See the sections for consulting activities and outside employment in chapter 2 of the Faculty Handbook 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 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).

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 in the new fiscal year, no further action is necessary; your disclosure will simply expire.

Outside activities include consulting and outside employment, which 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, review the sections for consulting activities and outside employment in chapter 2 of the Faculty Handbook for additional guidance and consult with your supervisor if you have questions. The director of the Research Conflict of Interest program is also available for consultations.

The disclosure system doesn’t ask for each of your clients because the university requires separate disclosures for each consulting client. A single disclosure denoting ownership of a consulting company with multiple unidentified clients does not allow an adequate assessment by university officials. If you have an unidentified, U.S.-based client and will receive >$5,000 from or any equity in that entity, contact coi@vt.edu to determine if you have additional disclosure requirements. If you are consulting for a client that is headquartered outside of the U.S., contact oesrc@vt.edu  for a reportability 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 apply to faculty participation in outside activities include chapter 2 of the Faculty Handbook (the sections for consulting activities and outside employment) and the University Facilities Usage and Events policy (No. 5000). 

Contact the Research Conflict of Interest program with questions about disclosing and the Disclosure and Management System. There are user guides for the Disclosure and Management System for disclosers as well as approvers of faculty outside activity disclosures.

If, after reading the sections for consulting activities and outside employment in chapter 2 of the Faculty Handbook, there is ambiguity about whether something is professional service, 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 do not 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, contact coi@vt.edu 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 apply to faculty participation in outside activities include chapter 2 of the Faculty Handbook (the sections for consulting activities and outside employment) 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 and not a financial conflict of interest. Financial conflicts of interest are related to financial information and are the responsibility of the Research Conflict of Interest 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 Conflict of Interest 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 sections for consulting activities and outside employment in chapter 2 of the Faculty Handbook.

The system, which is designed to reduce duplicate disclosure, automatically loops in relevant stakeholders when dictated by the circumstances (e.g., the Research Conflict of Interest 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, 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 address exceeding the time maximum include requiring the faculty member to 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.

Use form P-36 to request and receive permission for additional employment. See the Additional/Outside Employment Policy for Salaried Classified and University Staff policy (No. 4070)  and contact Human Resources 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.

See the COI/COC Requirements for Researchers site that is dedicated to this question.

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 the principal investigator. Exceptions include personnel or students whose research activities are directly supervised. 

The Research Conflict of Interest pogram 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 changes (e.g., when financial interests change).

Contact the Research Conflict of Interest program for a reportability assessment.

Investigators must disclose when they or an immediate family member receive/hold >$5,000 in annual payments and equity interest 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 or 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 of their financial interests in the context of their outside activity disclosures. In those cases, the Investigator will be prompted to annually certify that there are no changes to their financial interests. 

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 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 of their financial interests in the context of their outside activity disclosures. In those cases, the Investigator will be prompted to annually certify that there are no changes to their financial interests.

Yes. This disclosure considers 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 Conflict of Interest 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 changes (e.g., when financial interests change).

Maybe. 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 with the business (i.e., consulting and/or outside employment), 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. 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. Contact coi@vt.edu to discuss.

Contact the Research Conflict of Interest program. There are user guides for the Disclosure and Management System for disclosers as well as approvers of faculty outside activity disclosures.

A sponsored research management plan documents the strategies for managing a financial conflict of interest. It uses specific strategies to promote research objectivity, including mitigations to protect the academic and professional progression of graduate students and postdoctorals. 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. 

There are user guides for the Disclosure and Management System for approvers of financial conflict of interest management plans for sponsored research.