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Conflict of Interest and Commitment

Standard Operating Procedures for Conflicts of Interest and Commitment

To establish a standardized process in conjunction with Policy 1045 for the review and approval of disclosures submitted through the University’s centralized disclosure system.  As well as the identification, management, and monitoring for compliance of any resulting Conflicts of Interest or Commitment (COI/C).

This procedure applies to all employees, individuals designated as disclosing individuals as defined by Policy 1045 and to all personnel involved in the review and approval of disclosures, including:

  • Office of Conflicts of Interest and Commitment Services
  • Department Heads
  • Senior Leaders or their designees
  • Additional reviewing authorities as required by policy
  • Supervisors, when applicable

Disclosing Individuals (and employees with reportable activities/interests)

  • Submit complete and accurate disclosures.
  • Provide additional information when requested.
  • Refrain from initiating activities requiring prior approval until final approval is granted.

Office of Conflicts of Interest and Commitment Services

  • Administer the centralized disclosure system.
  • Monitor disclosure submissions and compliance requirements.
  • Conduct initial reviews of disclosures meeting review thresholds.
  • Identify potential conflicts of interest and commitment.
  • Provide guidance and recommendations to approvers.
  • Maintain disclosure records.
  • Coordinate appeal reviews.
  • Provide oversight of disclosure review activities.
  • Ensure consistency in application of policy and procedures.
  • Review escalated or complex disclosures as needed.

Department Heads

  • Review disclosures referred for departmental approval.
  • Evaluate operational impacts and potential conflicts.
  • Determine if disclosed activities or interests constitute a COI/C
  • Approve or disapprove disclosures in accordance with policy.

Senior Leaders or Designees

  • Provide secondary approval of Department Head disclosure reviews
  • Review disclosures of Department Heads
  • Evaluate institutional risks associated with disclosed activities.
  • Evaluate and adjudicate appeals of COI/C determinations or management

4.1 Disclosure Requirements

Activities and Interests that must be disclosed

All employees and graduate assistants on paid assistantships must disclose when they are, or anticipate being involved in any of the following activities:

  • Activities with international entities 
  • Board, officer, executive, or fiduciary roles 
  • Secondary Employment (Inside or Outside of VT) and appointments (including courtesy/honorary) 
  • Professional Services valued* at ≥$5,000/year 
  • Research-related activities or external research support 
  • Consulting activities 
  • Equity of any type or amount 
  • Activities/interests valued* at ≥$5,000/year 
  • Does, or is likely to do, business with VT   

Disclosure in advance of starting a new activity is required for all reportable activities except for those of immediate family and Professional Services valued* at less than $5,000/year.

*For purposes of this process, Value includes all compensation, complimentary travel, covered fees or registration costs, and any resources (e.g. funding, personnel, equipment, space, data) made available or provided by the entity.

 For additional information and guidance on disclosure requirements including examples of various activities or interests that must be disclosed, please refer to Activities and Interest Disclosure Guidance.

Initial Disclosures

  1. Employees identified as Disclosing Individuals must submit an initial disclosure within 30 days of their start day or prior to initiating an activity that requires disclosure in advance, whichever occurs first.
  2. All other employees must disclose prior to initiating an activity that requires disclosure in advance, or within 30 days of acquiring an interest or activity that does not require disclosure in advance.

Ongoing Updates

New activities or interests that do not require disclosure in advance should be completed within 30 days of initiating the new activity

Annual Certification of Disclosures

Disclosing Individuals and any employee with a disclosed activity or interest will review their current disclosure, update any information as necessary to ensure and certify the information is current, complete, and accurate. 

  1. These annual certifications will be divided into two groups as follows:
    1. Employee annual certification period will begin in December with all certifications due by January 31st.
    2. Graduate Assistants on paid assistantship annual certification period will begin in August with all certifications due by September 30th. 
  2. Annual certification is required even if no changes have occurred and the disclosure information remains the same. 

 

4.2 Administrative Review

Disclosures with no reported activities or interests

System will automatically approve the disclosures upon submission, no central or Department Head approval required.

4.3 Central Administrative Review Process

Any disclosure with a reported activity or interest will be routed to the appropriate central office for review based on the minimum thresholds for review as established by each office.   The Office for COI/C Services reviews all disclosed activities with no minimum threshold for review.

  1. Central reviews are conducted concurrently and can be coordinated based on need.  These additional reviews may include Procurement, Research Security, Research COI Program, and HR.  Additional information on other review processes are available on the COI website.
  2. The preliminary review by the Office of COI/C Services applies a decision rubric to evaluate each disclosed entity to distinguish higher risk activities and interests for creating conflicts of interest or commitment.
    a)The decision rubric is a risk assessment tool and does not establish that a COI/C exists.
    b)The rubric helps identify if activities or interests warrant further review or potential COI/C.
  3. Disclosers may be required to provide additional information, including copies of external agreements and contracts including:
    a)Employment or appointment contracts and letters
    b)Consulting or advisory board agreements
    c)Grant applications submitted outside of Virginia Tech (such as SBIR/STTR)
  4. The Office of COI/C Services may consult relevant offices as necessary to complete the preliminary review.
  5. The Office of COI/C Services does not give final approval for activities, interests, or disclosures.  Final approvals and determinations are made by: 
    a)Department Head and Senior Leader (or designee) for most employees 
    b)Senior Leader (or designee) for Department Heads and Senior Leaders  
  6. Outcomes of this preliminary review are coalesced with review outcomes of the other offices and provided to responsible reviewers for final review and determinations of any COI/C. Outcomes of the preliminary review may include:
    a)No activities or interests of increased risk for possible conflicts of interest or commitment identified.
    b)Activities or interests that warrant focused review due to potential higher risk for conflicts of interest or commitment.
    c)Identification of likely conflicts of interest or commitment.
    d)Identification of activities or interests that will require alteration or an exception granted to comply with state code or university policy.

4.4 Departmental and Leadership Review

Standard Review Path

  1. Utilizing the Conflicts of Interest and Commitment Areas of Review and Consideration for Approvers, the Department Head reviews the disclosure and recommendations.  Activities and interests are evaluated across a number of domains, including but not limited to:
    a)Job Performance
    b)Loyalty/influence
    c)Time commitment (for professional activities and personal)
    d)Resource overlap
    e)Competition with Virginia Tech
  2. Department Heads should consult with the Office of COI/C Services for any questions or concerns when evaluating a disclosure.  The Office of COI/C Services can be a resource for:
    a)Applicability/interpretation of state code or university policy
    b)Precedent from prior determinations within the college or across the university
    c)Options for possible resolution or management strategies
  3. Outcomes from the Department Head review may include:
    a)No COI/C exists with recommendation the disclosure be approved.
    b)A COI/C does not currently exist although could under certain circumstances.  Recommendation is for the disclosure to be approved along with an email to the discloser, with a copy to the Office of COI/C Services, on necessary steps to either pre-emptively mitigate or to avoid a COI/C.
    c)A COI/C exists and recommends management be implemented.
    d)A relationship with an entity creates a COI/C that cannot effectively be managed and recommends the relationship be discontinued or not initiated.
  4. Department Head determinations and recommendations are sent to the corresponding Senior Leader or designee for final review of the disclosure.
  5. Senior Leader or designee reviews the disclosure and recommendations utilizing the Conflicts of Interest and Commitment Areas of Review and Consideration for Approvers. 
    a)Senior Leader review process follows the same process as Department Head.  Senior Leaders should resolve any discrepancies between Department Head and Senior Leader determinations, although final authority rests with the Senior Leader.

Department Head or Senior Leader Disclosures

  1. Disclosures submitted by Department Heads or Senior Leaders require only one level of approval.
  2. Approval authority will be assigned according to established delegation standards.

4.5 Supervisor Notification

  1. When the Department Head is not the employee’s direct supervisor, relevant disclosure information may be shared with the supervisor for awareness or as needed to complete the review.
  2. Supervisors receiving information are expected to maintain confidentiality consistent with University policy.

4.6 Review Outcomes

  1. No COI/C exists.  The review is complete and no further action is required.  The status of the disclosure is updated to reflect the outcome.
  2. No COI/C exists, with email reminder to discloser.
    a)Due to certain activities a reminder email will be sent to discloser by either the Department Head or Senior Leader/designee, with copy to the Office of COI/C Services on necessary steps to avoid a future COI/C or to comply state code/university requirements. 
  3. A COI/C exists and management is required.
  4. An activity or interest creates an unmanageable COI/C and must be discontinued or not initiated. 
    a)For existing activities, a management plan will be implemented outlining the requirement to discontinue the relationship with an expected timeline included.
    b)For pending activities, the discloser will be notified the disclosed activity was not approved.

    Note: Individuals may appeal a determination as described in section 6 of this procedure.

4.7  Notification to Disclosing Individual

  1. Individuals may review disclosure status at any time through the disclosure system. 
    a) No automated notifications are generated when an individual successfully submits a disclosure or the review is complete and no conflicts were identified.
    b) The discloser will be notified when a management plan has been issued to them requiring their review and acceptance. 

Review outcomes resulting in a determination of a COI/C requiring management will be documented with a formal management plan as follows:

  1. The Senior Leader/designee will consult with the Department Head and Office of COI/C services on the specifics of the conflict and the mitigating strategies to be enacted.
    a) The Office of COI/C Services can assist in identifying appropriate strategies to effectively manage the conflict.
  2. The Office of COI/C Services will draft the management plan using a standardized template and wording, at minimum:
    a) Identifying the entity(ies) and corresponding activity(ies) that resulted in the COI/C determination, along with any rational for how the relationship creates a conflict.
    b)The list of mitigating strategies to be implemented to mitigate the COI/C, including timelines for when implementation must be completed, and monitoring requirements.
    c) The plan is addressed to the individual with the Senior Leader as primary contact with copies to the Department Head, Office of COI/C Services, and other individuals deemed essential such as the Research COI Program or Supervisor.
  3. The draft management plan will be sent for review and approval by the Senior Leader/designee
  4. Upon approval of the draft, the management plan will be sent via the centralized disclosure system for review and acceptance by the individual.  The individual may appeal either the determination or part/all the management plan.

For additional information and guidance, refer to the COI/C Management Strategies Guidance.

  1. Individuals who disagree with a disclosure determination or a subsequent COI/C management plan may submit an appeal.
  2. The appeal is initiated either by contacting the Senior Leader/designee issuing the determination and the Office of COI/C Services, or by rejecting a management plan issued through the central disclosure system.
  3. The appeal may include:
    - Meeting with the individual, senior leader/designee, Department Head, and Director of COI/C Services
    - Requirements for additional supporting information or clarifications
    - Documentation relevant to the disputed determination.
  4. The appeal will be reviewed by appropriate senior or executive leadership within the individual’s reporting structure. 
  5. The resulting determination is final and will be communicated via email.
  6. This appeals process is only applicable to COI/C determinations and management.  Research Financial Conflict of Interest (FCOI) matters are governed by separate standards and procedures and therefore excluded from this appeal process.

Monitoring for management plan adherence is the responsibility of the Senior Leader/designee and Department Head.  The Office of COI/C Services may periodically require confirmation that monitoring has been completed and compliance verified. 

The central disclosure system will be utilized for recording ongoing monitoring activities and to document compliance.

Additional tools, resources and guides are available:

  • Activities and Interest Disclosure Guidance
  • Code of Virginia – Conflicts of Interest Act Guidance
  • Frequently Asked Questions
  • Conflicts of Interest and Commitment Areas of Review and Consideration for Approvers
  • COI/C Management Strategies Guidance

  • 7/10/2026 Initial Release