Disclosure Guidance
Reminder: Any disclosure in the Disclosure and Management System must be submitted initially, renewed annually, and updated within 30 days of 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 conflict of interest stakeholders across the university. 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: Note that your disclosures to Virginia Tech and to federal sponsors in the proposal being submitted by the Office of Sponsored Programs must be consistent. Review the following guidance or contact foreigninfl@vt.edu.
Disclose if:
Faculty
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 changes.
Note that faculty disclose financial information related to their activity in a portion of the disclosure that is viewable by the Research Conflict of Interest program for financial conflict of interest assessment purposes. Note 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. See the FAQs page or the sections for consulting activities and outside employment in chapter 2 of the Faculty Handbook. Note that the terms for outside activities might vary across policies (e.g., external activities, external consulting, entrepreneurial activities, etc.).
For faculty engaged in sponsored research, continue to #2.
Staff
Salaried staff must disclose additional employment outside of the Disclosure and Management System. Use form P-36 to request and receive permission for additional employment. Review the Additional/Outside Employment Policy for Salaried Classified and University Staff policy (No. 4070) and contact Human Resources with any questions.
Students
Graduate students must disclose additional employment outside of the Disclosure and Management System in certain limited circumstances. 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 in the Research Financial Interest module. The Research Conflict of Interest 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 changes.
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.
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 disclosure is not routed for approval. It will route directly to the Research Conflict of Interest program for review and development of a management plan, if needed.
See the Researcher Requirements page for more information.
3. You or an immediate family member have a financial interest related to Virginia Tech contracting.
State law generally prohibits an employee (or their spouse/dependent children) from having a financial interest related to university contracting when they hold >3% ownership in or receive >$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.
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 changes (e.g., when financial interests change). The disclosure is not routed for approval, but is instead reviewed by the Research Conflict of Interest program and other stakeholders identified by the discloser. If required, the programs will reach out to you to coordinate next steps.
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.
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.