The Research and Innovation office manages Disclosure Guidelines and Requirements for outside activities/employment in compliance with Policy 13010: Individual Conflicts of Interest Commitment.
There are three circumstances that require employees to disclose to Virginia Tech in the Disclosure and Management System, which is used for disclosure submissions across the university in support of multiple policies. Please visit the Disclosure Guidance page for more information.
You want to engage in a work commitment outside your primary Virginia Tech appointment:
Faculty and staff must request and receive prior approval for participation in additional work commitments. Supervisors will assess whether the additional commitment represents a conflict of commitment, a situation in which the employee has overcommitted to multiple employers or entities. This is an employee-initiated disclosure, routed to their supervisor for approval. Faculty must disclose outside activities (i.e., consulting and outside employment) using the Disclosure and Management System. Staff must disclose additional employment (at or outside of Virginia Tech) using form P-36 in accordance with Policy 4070. For faculty approvers, please see the Approving Faculty Outside Activity Disclosures section on the FAQ page for more information.
Graduate students on an assistantship must disclose additional employment to Virginia Tech in the manner prescribed in the Graduate Catalog. Contact the Graduate School with questions.
You participate in research as an Investigator:
For employees engaged in sponsored research with the level of responsibility similar or equivalent to a principal investigator, financial interests that reasonably appear related to the Investigator’s institutional responsibilities must be disclosed in the Disclosure and Management System. The RCOI Program will notify you if you meet the definition of an Investigator for this purpose.
You or an immediate family member have a financial interest in a business/vendor that is a party to a contract/transaction with Virginia Tech (i.e., a sponsored project or procurement):
An employee must disclose through the Disclosure and Management System if the employee or their immediate family member a) holds >3% of the total equity in or b) receives >$5,000 in annual payments from the business. For employees who disclose in the Disclosure and Management System in the context of numbers 1 or 2 above, this requirement only applies if there will be a purchase of goods or services from the entity. This is an employee-initiated disclosure.
Initial disclosures must be submitted before the additional work commitment, sponsored research, or university contract begins. Disclosures in the Disclosure and Management System must be updated within 30 days of any changes and renewed annually, as needed.
The purchase of goods and services by the university from a business or entity owned by a university employee, or by a member of the employee’s immediate family, is a prohibited conflict of interest under state law. The conflict exists even if the purchase is being made by a department/unit other than the employee’s home department. An exception to this prohibition can be granted in certain circumstances if disclosure requirements to the university and other conditions are met. Single onetime purchases valued at $500 or less are exempt from this requirement.
Contact your department head or supervisor (faculty) or your supervisor or HR (staff) with questions about additional work commitments.
Contact the RCOI Program at mailto:coi@vt.eduwith questions about Investigators, financial interests related to sponsored research and sponsored projects, or technical concerns involving the Disclosure and Management System.
Contact Procurement at mailto:procurement@vt.eduwith questions about financial interests related to purchasing contracts/transactions.
RELATED POLICIES AND PROCEDURES
Please visit the Virginia Tech Policy Library for a comprehensive list of policies and procedures.
Policy 13010: Individual Conflicts of Interest and Commitment
Policy 3005: University-Related Business and Commercial Activities
Policy 4070: Additional/Outside Employment Policy for Salaried Classified and University Staff
Graduate Catalog: Graduate students (those holding assistantships): Additional Employment for Students Holding a Graduate Assistantship
Procurement: Conflicts of interest in purchasing
Foreign Influence in Federally Sponsored Research – Guidance