Conflict of Interest and Commitment Requirements for Researchers
Overview
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. In summary, investigators must annually disclose financial interests related to their institutional responsibilities and exceeding certain thresholds and take financial conflict of interest training in CITI every four years. The university requires sponsored research awards to be held until these requirements are met. Investigator requirements apply to those currently on the study team as well as researchers who are onboarded after award and meet the Investigator definition.
Note that the Research Conflict of Interest program will notify you when you meet the definition of an Investigator and must disclose/take training, but you must independently update your research financial interest disclosure within 30 days of changes.
If there are steps necessary to comply with state law, the Research Conflict of Interest program will assist the investigator in applying for the approvals needed. There is a particular significance to research conflict of interest processes when a faculty member has a financial interest in a small business that is pursuing SBRI/STTR funding in collaboration with Virginia Tech. The dedicated SBIR/STTR Guidelines page provides additional information intended to guide faculty as they prepare SBIR and STTR proposals and manage grant subawards.
Investigators must disclose certain financial interests that are related to their institutional responsibilities in the Research Financial Interest Disclosure 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. Note that 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. If an employee involved in the research does not meet the definition of Investigator but has a financial interest related to the research, the employee should contact the Research Conflict of Interest program for a reportability assessment.
See the Disclosure Guidance page for more information.
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 in the proposal being submitted by the Office of Sponsored Programs. If you have questions about what should be disclosed to the federal sponsor in the proposal, review the following guidance or contact foreigninfl@vt.edu.
Instructions for Accessing the Financial COI Training Requirement for Sponsored Research in CITI
The Research Conflict of Interest program has streamlined the training process to create a better experience for Investigators and will notify you as your training becomes due.
Investigators must take financial conflict of interest training every four years in CITI (the Collaborative Institutional Training Initiative Program). Virginia Tech applies the same disclosure and management principles to all sponsored research, regardless of sponsor. Therefore, the training requirement applies to all Investigators on sponsored research projects.
Note the training requirement is in addition to the Commonwealth of Virginia-Specific Conflict of Interest training required for Statement of Economic Interest (SOEI) filers. Human Resources will contact employees directly if this training requirement applies to them, including the deadlines for completion. See the Disclosure to the Commonwealth of Virginia section below for more SOEI filer information.
Once an Investigator discloses a financial interest to the university, the Research Conflict of Interest program determines whether the financial interest could directly and significantly affect the design, conduct, or reporting of research. If so, the situation represents a financial conflict of interest (FCOI) and the program must ensure that a plan to manage the financial interest is developed and implemented prior to the start of the research. The management plan must be accepted by the financial interest holder and their department head/supervisor.
An FCOI assessment is based on the factual context of the situation and is not based on any implied judgment about the character or intent of the individual.
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. If needed, 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.
Management plan terms are formalized and accepted in the Disclosure and Management System. There are user guides to help you approve the plan put into place by the program.
While the Investigator with an FCOI bears primary responsibility for carrying out the plan, supervisors are expected to monitor compliance. As described in the management plan, the Investigator and individuals engaged in oversight will be periodically requested to provide an update on the fulfillment of the management plan’s terms.
In addition to your Virginia Tech disclosures and training, 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 their financial interest related to research or other Virginia Tech contracts.
Human Resources maintains the list of employees required to file the Statement of Economic Interests and will be in contact if this disclosure requirement applies to you. See Human Resource’s SOEI website for more information.